United States Off ice of EPA-130/1-79-001
Environmental Protection Federal Activities May 1979
Agency Washington, D.C.
<>EPA Floodplain Development Pressures
and Federal Programs,
Part 1: Case Study Analysis and
Recommendations for The "20V
Wastewater Treatment Works Program
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EPA-130/1-79-001
Floodplain Development Pressures
and Federal Programs
ERRATA SHEET
Page.
ill Line 22 should read: A. Introduction
Line 27 should read: Floodplain Development Pressures
4 Line 14 should read: ...used in implementing the National
Line 32 should read; floodplain, found close to the stream channel.
22 Line 7 should read: a wide range of federal programs was discussed,...
Lines 14 and 15 should read: ...Figures 5 through 10 summarize...
Lines 25 and 26 should read: 5 pertains to case studies in the Atlanta
region, Figure 6 pertains
Line 28 should read: Figure 7 pertains to the Denver
Lines 33 and 34 should read: Figure 8 pertains to case studies in the
Atlanta region. Figure 9
Line 36 should read: and Figure 10 pertains to...
28-
30 Figures 8, 9, and 10, first federal program should read: '201' Wastewater
Treatment Works Program - EPA
37 Line 4 should read: ...Department of Agriculture were expected
42 Line 40 should read: observations summarize ,,.
58 Line 14 should read: communication and coordination are needed...
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Two additional volumes were prepared in support of this
report. Part II identifies methods presently used by federal
programs to mitigate floodplain impacts and presents a detailed
analysis of decision points for floodplain impact mitigation
in the '201' Wastewater Treatment Works Program. It is titled
'Floodplain Development Pressures and Federal Programs, Part II:
Methods Used by Federal Programs to Reduce Floodplain Develop-
ment Pressures.1 Part III describes the location and major
findings from each of the thirty^-one case studies of floodplain
development pressures. It is titled 'Floodplain Development
Pressures and Federal Programs, Part III: Case Study Reports.'
This document and the two documents noted above are
available to the public through the National Technical Infor-
mation Service, Springfield, Virginia 22161.
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AUG 4 1982
EPA 130/1-79-001
FLOODPLAIN DEVELOPMENT PRESSURES AND FEDERAL PROGRAMS,
PART I: CASE STUDY ANALYSIS AND RECOMMENDATIONS FOR THE
'201' WASTEWATER TREATMENT WORKS PROGRAM
Contract No. 68-01-3923
Project Officer
Randal S. Scott
Office of Federal Activities
Prepared for
Office of Federal Activities
U.S. Environmental Protection Agency
Washington, D.C. 20460
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This report has been reviewed by the Office of Federal
Activities, U.S. Environmental Protection Agency, and approved
for publication. Approval does not signify that the contents
necessarily reflect the views and policies of the U.S. Environ-
mental Protection Agency, nor does mention of trade names or
commercial products constitute endorsement or recommendation
for use.
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TABLE OF CONTENTS
Page
EXECUTIVE SUMMARY V
PART I: ANALYSIS AND RECOMMENDATIONS
CHAPTER ONE: AN INTRODUCTION TO FLOODPLAIN
DEVELOPMENT IMPACTS RELATED TO
WASTEWATER TREATMENT FACILITIES
A. Introduction 1
B. Purpose of the Study 2
C. Definition and Importance of the
Floodplain 4
D. President Carter's Floodplain Manage-
ment Executive Order 6
E. Previous Studies: Wastewater Treat-
ment Facilities and Secondary Impacts 7
1. Interceptor Sewers and Suburban
Sprawl 8
2. Mitigating Secondary Impacts from
the Wastewater Facilities Program 10
3. National Wildlife Federation
Evaluation 12
CHAPTER TWO: RESEARCH METHOD AND MAJOR FINDINGS
A. Introdution 16
B. Case Study Method 17
C. Federal Programs and Floodplain Develop-
ment Impacts 22
D. Present Approaches to the Reduction of
Floodplains Development Pressures 42
1. Riverside Lakes Project, Nebraska 44
2. Wastewater Treatment Facility Pro-
ject in Meridian, Mississippi 47
111
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CHAPTER THREE: CONCLUSIONS AND RECOMMENDATIONS FOR
THE IDENTIFICATION AND REDUCTION OF
FLOODPLAIN DEVELOPMENT IMPACTS
A. Introduction 51
B. Summary of Key Findings 53
1. Identification of Floodplain Devel-
opment Pressures and the '201' Pro-
gram Planning Process 54
2. Coordination Between the U.S. Envir-
onmental Protection Agency and the
Federal Insurance Administration 58
3. Definition of Criteria and Standards
for Floodplain Development Impacts 59
4. Use of Grant Conditions for Sewer
Hookup Restrictions 60
5. Definitions of Criteria and Standards
for Floodplain Development Impacts 62
IV
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EXECUTIVE SUMMARY
FLOODPLAIN DEVELOPMENT PRESSURES AND FEDERAL PROGRAMS
SUMMARY OF FINDINGS AND RECOMMENDATIONS
Between October, 1977 and June, 1978, a study of floodplain
development pressures and federal programs has been carried
out at the request of the Office of Federal Activities of
the U.S. Environmental Protection Agency. The study re-
commends ways in which EPA can reduce floodplain develop-
ment pressures caused by the '201' Wastewater Treatment
Works Program.
The following information was collected and researched in order
to recommend appropriate approaches to EPA:
1. Thirty-one case studies of floodplain development
pressures in the Midwest, West, and Southeast re-
gions were conducted. The degree to which certain
federal programs have affected floodplain develop-
ment was assessed in the case studies.
2. Meetings with EPA Regional Offices in Atlanta,
Kansas City, and Denver were held to review present
methods and approaches for mitigating floodplain
development pressures caused by '201' wastewater
treatment facilities. Contacts with Regional
Offices of the Federal Insurance Administration
were also made.
3. Interviews with federal officials were conducted
and federal program regulations reviewed to iden-
tify methods presently being used by federal agencies.
4. Major decision points in the '201' Wastewater Treat-
ment Works Program which can affect floodplain devel-
opment were identified.
The findings from the research and recommendations for the
'201' Wastewater Treatment Works Program are presented in
a three-volume report. Major findings and recommendations
from the study are summarized below.
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Federal Programs and Floodplain Development;
1. Three federal programs were observed to encourage
or allow urban development to take place. These
programs include:
'201' Wastewater Treatment Works Program -
U.S. Environmental Protection Agency;
Federal-Aid Highway Program - U.S. Depart-
ment of Transportation; and
Public Works Program (levee and dam con-
struction) - U.S. Army Corps of Engineers.
In some cases, the urban development which was
facilitated occurred in floodplain locations.
In other cases, federal programs caused general
community development.
2. The highest incidence of community development
pressures came from the '201' Wastewater Treatment
Works Program which was observed by persons inter-
viewed to allow or encourage development in approxi-
mately 2/3 of the cases. In 16 out of 31 cases,
the '201' Program allowed development to occur. In
only 6 out of 31 cases, the program had the effect
of encouraging development throughout the community.
3. Federal programs were not the major stimulus of
floodplain development in most cases. Most federal
programs had been obtained by local communities to
improve community life for persons already living in
the area.
4. No federal programs were noted as having encouraged
development in the floodplain, although several
were found to allow development in the floodplain
to occur. This finding reflects the fact that
many case study communities receiving '201' Waste-
water Treatment Facility grants did not have
development in the floodplain.
5. Two federal programs were found to discourage flood-
plain development. These programs include the
National Flood Insurance Program of the U.S. Depart-
ment of Housing and Urban Development and the Land
and Water Conservation Fund Program of the Heritage
Conservation and Recreation Service.
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Present Approaches to the Reduction of Floodplain Development
Pressures;
1. Floodplain development impacts caused by waste-
water treatment facilities are usually identified
by EPA Regional Offices when environmental reviews
are completed. An environmental review is usually
conducted after the Step 1 Facility Plan has been
prepared.
2. Major floodplain development questions and issues
have arisen for only a small number of '201' Waste-
water Treatment Facility projects. When issues do
arise, discussions and coordination with the Federal
Insurance Administration often occurs. Formal pro-
cedures for FIA and EPA coordination have not been
developed, however.
3. Grant conditions which restrict hookups in floodplains
are sometimes used by EPA Regional Offices as a
method for reducing floodplain development impacts.
EPA Regional Office staff question, however, whether
the grant conditions can be enforced after final
payment on the '201' grant has been made. Other
approaches such as the redesign of the facility are
also used, although they frequently result in some
project delays. Delays occur because the floodplain
development issue is not identified until after the
Step 1 Facility Plan has been completed.
Methods Used by Federal Programs to Control Floodplain Develop-
ment:
1. Approaches used by federal programs to identify and
mitigate floodplain development pressures may be
organized into three categories:
Regulation of land uses in the floodplain,
either by state, federal, or local agencies;
Policies concerning floodplain development,
including design standards for flood hazard
protection, location criteria, and natural
resource protection policies; and
. Environmental impact assessments carried out
during the project planning process in com-
Vll
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pliance with the National Environmental
Policy Act (NEPA).
The use of environmental impact assessment procedures
is the predominant method used by federal programs.
The review of federal programs was completed during
the Fall of 1977, prior to the implementation of
the Floodplain Management Executive Order. It
is expected that NEPA procedures together with new
"floodplain impact notice" procedures will be the
dominant federal approaches in the future.
2. Although several federal programs require the devel-
opment and implementation of regulatory programs for
the control of land and water uses, the National
Flood Insurance Program is the only program pro-
viding incentives for the regulation of the entire
floodplain. Although the focus of the National
Flood Insurance Program is flood hazard protection,
the program often discourages floodplain development.
This fact is documented in several of the floodplain
development case studies.
3. Three federal agencies, including the Federal Highway
Administration, the Environmental Protection Agency,
and the Farmers Home Administration have developed
specific policies relating to the location of facili-
ties and structures in floodplains. In each case,
the policies direct facilities to locations outside
of floodplains, whenever possible.
4. The U.S. Environmental Protection Agency is the only
federal agency with specific policies on secondary
impacts (Program Guidance Memorandum #50, titled
"Consideration of Secondary Environmental Effects
in the Construction Grants Process"). The policy
statement directs EPA administrators and agencies
receiving '201* grants to fully consider secondary
impacts during the environmental impact assessment
process. Agencies are encouraged to mitigate
" secondary impacts by phasing sewer service, revising
projects, and restricting treatment facility use
after construction.
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5, All agencies contacted for this study complete
environmental assessments of proposed actions in
compliance with the National Environmental Policy
Act. The degree to which floodplain impacts are
identified and assessed varies among federal agencies
and also varies among specific projects considered
by each agency.
Decision Points in the '201' Wastevater Treatment Works Program
Related to Floodplain Development Impacts;
1. The '201' Wastewater Treatment Works Program is
organized into three stages, called steps. During
Step 1, the grantee prepares a Facility Plan
which reviews alternative approaches to wastewater
treatment facility needs and recommends an approach.
During Step 2, detailed engineering designs are
prepared. During Step 3, facility construction
takes place. EPA review and approval takes place
prior to each step. Separate grants are made for
planning, design, and construction activities.
2. Important decisions are made by EPA prior to the Step
1 grant. The review and approval of the "priority
list" of projects for funding which is prepared
by state agencies is of special note.
3. Several types of decisions, made at different points
in the '201' process, can affect the impact of a
facility on floodplain development. As indicated
below, according to EPA regulations and .guidelines,
the Step 1 facility planning process is the proper
time to identify floodplain development impacts and
alternative approaches for reducing and mitigating
impacts. The types of decisions and their relation-
ship to the '201' process are as follows:
Decisions related to the location of the
facility; Because development often occurs
around a treatment plant and interceptor, even
when service to the area is not anticipated,
decisions related to the location of wastewater
treatment facilities can influence floodplain
development impacts.
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Considerations related to the location of the
facility occur pyior to the approval of a
Step 1 grant, when the preliminary project
boundary for the Facility Plan is identified.
The specific location for the facility is
determined during Step 1 facilities planning.
Decisions related to the size, capacity, and
service area of the facility; Decisions related
to the physical capacity and size of the treat-
ment facility, as well as the area serviced,
affect growth and development. Most '201'
projects provide for growth which is projected
to occur over a 20 year period.
Detailed planning for the size, capacity, and
service area of the facility takes place during
Step 1. When the Step 1 Facility Plan is re-
viewed by the EPA Regional Office, further
consideration is given to the proposed size, capa-
city, and service area.
Decisions related to facility staging and
hookup; After the existing and projected
population to be served has been determined,
the staging of construction and hookup pro-
visions can be determined. Such policy deci-
sions can provide for the limitation of develop-
ment in floodplains.
Decisions related to staging of the facility and
hookups also should occur during the Step 1
facility planning'process. The Step 1 Facility
Plan must' identify ways to mitigate environmental
impacts related to the facility. When the EPA
Regional Office considers the Step 1 Facility
Plan, proposals for facility staging and re-
strictions of hookups are also considered.
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Recommendations for Reducing Floodplain Development Pressures
Resulting from '201' Wastewater Treatment Facilities;
1. Identification of Floodplain Development Pressures
and the '201' Program Planning Process;
Although floodplain development pressures should be
identified and considered during Step 1 facility
planning, this identification typically does not \
occur. Instead, EPA Regional Office staff identify
issues during the environmental review which ocflurb
after the Step 1 Facility Plan has been completed.
In order to encourage and facilitate a thorough
review of floodplain development pressures during
the Step 1 stage, it is recommended that EPA Regional
Offices identify those facility projects which are
likely to create development pressures prior to
the Step 1 grant. This identification can be carried
out from the state project priority lists without
extensive study. Project boundaries should be com-
pared with general floodplain boundary information
available through the Federal Insurance Administration
and through contacts with Federal Insurance Admini-
stration staff who are familiar with floodplain
development in many communities in their region.
2. Coordination Between the U.S. Environmental Pro-
tection Agency and the Federal Insurance Admini-
stration;
The Federal Insurance Administration, through the
National Flood Insurance Program, is devoting signi-
ficant resources to floodplain information and
management concerns. The FIA Regional Offices are
willing and interested in providing assistance and
information to EPA Regional Offices on a request
basis.
It is recommended that more extensive information
exchange and coordination between FIA and EPA occur
in the future. EPA staff should be provided with
information about floodplain hazards, development
issues, and the National Flood Insurance Program.
FIA should be informed about EPA policies concern-
ing floodplain development.
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In order to facilitate the communication and
organization of appropriate meetings and workshops,
it is recommended that a floodplain coordinator be
designated in each EPA Regional Office. The
designated coordinator would initiate appropriate
meetings and seminars, monitor the implementation
of floodplain policy within each EPA Regional Office,
and could complete the floodplain impact reviews
recommended previously.
3. Federal Agency Coordination for Floodplain Impact
Mitigation;
Although there is no typical sequence or pattern in
which federal programs occur in local communities,
federal agency coordination in specific cases is
recommended. Coordination should occur when two
federal agencies are considering projects which may
affect the same floodplain area. In such cases,
it is essential that the agencies have similar
policies and approaches.
The problem faced by EPA Regional Offices in imple-
menting this recommendation is the identification
of other federal programs. Such an identification
could be requested through the Step 1 Facility Plan
and considered by EPA Regional Offices when the
Step 1 Facility Plan is submitted for review. The
coordination with other federal agencies should
take place as early as possible in the planning
process.
4. Use of Grant Conditions for Sewer Hookup Restrictions:
The use of grant conditions for sewer hookup restric-
tions is one of several floodplain development miti-
gation measures available to the U.S. Environmental
Protection Agency. Grant conditions are most useful
when floodplain development pressures are discovered
after the Step 1 Facility Plan has been completed.
Typically, this is the case with the '201' Program.
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The EPA Office of General Counsel has determined
that grant conditions on Step 2 and Step 3
grants do extend beyond the payment period and can
be enforced through court action. It is, therefore,
recommended that EPA Regional Offices be informed
of the utility and enforceability of grant conditions
and be encouraged to use this approach, in addition
to other mitigation measures.
5. Definition of Criteria and Standards for Floodplain
Development Impacts;
In some cases, floodplain development pressures can-
not be avoided. In such cases, it may be possible
to reduce hazardous conditions and development
impacts if certain steps are taken. It is important
that each EPA Regional Office develop appropriate
criteria and standards related to floodplain develop-
ment for use in such cases. It is recommended that
each EPA Regional Office monitor EPA decisions on
floodplain development impacts and work closely
with FIA Regional Offices in the development of
such criteria and standards.
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CHAPTER ONE
AN INTRODUCTION TO FLOODPLAIN DEVELOPMENT IMPACTS RELATED
TO WASTEWATER TREATMENT FACILITIES
A. Introduction
Urban development in floodplains can create numerous environ-
mental and safety problems. Development in floodplains is
frequently subject to hazardous flood conditions which en-
danger lives as well as property. Floodplain development
can damage sensitive environmental resources such as wet-
lands and can also increase flood heights and hazards
downstream.
It is the policy of the U.S. Environmental Protection Agency
to avoid the construction of wastewater treatment facilities
in floodplains whenever possible. Due to engineering and cost
reasons, however, treatment plants and interceptors are often
located in floodplains. When interceptors pass through unde-
veloped floodplain lands, the presence of sewage treatment
facilities can be an incentive for further floodplain develop-
ment.
Flood impacts can, therefore, be classified into two categories:
(1) primary impacts, and C2) secondary impacts. Primary impacts
are changes which directly result from the construction and
operation of a facility. For example, a sewer interceptor
may destroy an archaeological site or raise the level of down-
stream flood waters.
In contrast, secondary impacts are indirect or induced changes.
Land use development stimulated by facility construction is a
major secondary impact which is of environmental concern.
Secondary impacts, although more difficult to identify or pre-
dict, often create more environmental damage than primary im-
pacts from the construction of a treatment plant. The poten-
tial for secondary development impacts from wastewater treat-
ment facilities is a continuing concern of the U.S. Environ-
mental Protection Agency and is the focus of this study.
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The identification and reduction of floodplain development
pressures from federal programs is an inter-agency task. If
the actions of one agency promote floodplain development while
other agencies are trying to reduce floodplain development
pressures, uniform federal policy cannot be achieved.
The U.S. Environmental Protection Agency presently has in effect
a series of regulations and guidelines pertaining to the iden-
tification and mitigation of environmental impacts, including
secondary development caused by wastewater treatment facilities
and need for floodplain protection. The policies of EPA have
been reinforced by the May, 1977 Executive Order on Floodplain
Management issued by President Carter which clearly states that
federal programs should avoid floodplain development impacts.
Agencies in Washington, D.C. are presently working together
to identify and implement uniform guidelines in response to
the Executive Order.
There is, however, a continuing need to examine the impacts of
federal programs and projects on floodplain development, and a
continuing need to explore new ways of mitigating adverse
impacts. Mitigation measures may include new administrative
techniques or legal approaches, as well as new applications of
existing techniques. In some cases, two or more agencies can
work together and save each agency time and effort.
B. Purpose of the Study
The purpose of this study is to identify the individual and
combined effect of federal programs on development in the
floodplain and to recommend ways in which the '201' Waste-
water Treatment Works Program of the U.S. Environmental Pro-
jection Agency can reduce floodplain development pressures.
The following research was completed as background for re-
commendations to the '201' Wastewater Treatment Works Program:
1. Thirty-one case studies of the impact of federal
programs on floodplain development were completed
in the Southeast, West, and Midwest regions.
Interviews with planning directors and other
knowledgeable persons at the local government
level provided the basic information;
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2. Meetings with the EPA Regional Offices in Atlanta,
Kansas City, and Denver were held to review pre-
sent methods for implementing floodplain policy
related to '201' wastewater treatment facilities;
3. Federal programs which potentially can affect
floodplain development were reviewed to identify
the range of methods and approaches presently
used to mitigate floodplain development pressures;
and
4. Major decision points in the '201' Wastewater Treat-
ment Works Program which can affect floodplain im-
pacts were identified, based upon a review of
program regulations and guidance materials.
The findings from the case studies, the results of the EPA
regional office meetings, and recommendations for the '201'
Wastewater Treatment Works Program are presented in Part I
©f this three-volume report.
Two additional reports present detailed information and analysis
from the study. Part II identifies methods presently used by
federal programs to mitigate floodplain impacts and presents
a detailed analysis of decision points in the '201' Wastewater
Treatment Works Program. Part III describes the location and
major findings from each case study of floodplain development
pressures.
As an introduction to the findings and recommendations on
floodplain development impacts and the '201' Wastewater
Treatment Works Program, the following topics are reviewed
in this chapter:
Definition and importance of the floodplain;
President Carter's Floodplain Management Executive
Order; and
Previous studies related to wastewater treatment
facilities and secondary development.
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Chapter Two of this report documents the methods and findings
from the community case studies and from EPA Regional Office
meetings. Chapter Three presents the recommendations for
the '201' Wastewater Treatment Works Program.
C. Definition and Importance of the Floodplain
Floodplains are lowland areas adjacent to rivers, streams,
ponds, and oceans which are subject to periodic inundation.
The natural function of the floodplain is to hold and retain
excess amounts of water during times of river or tidal floods.
Most rivers overflow their banks every one and one-half to
two years, although the most severe floods occur at less
frequent intervals. The 100-year flood, a flood which has a
one percent possibility of occurring in any given year, is
the floodplain definition used in implementating the Natural
Flood Insurance program administered by the U.S. Department of
Housing and Urban Development. For purposes of this study,
the floodplain has been considered as equivalent to the 100-
year floodplain.
When urban development takes place in the floodplain, incon-
venience, hardship, danger, and both environmental and
economic losses may result. Flood waters take a high toll
on developed property each year, and in severe storms can en-
danger lives as well as property.
Construction in the floodplain reduces the vegetative cover
which slows the force of the waters. The vegetation of the
floodplain also absorbs sediments and pollutants from upstream
areas. The natural value of floodplains is reduced when cer-
tain types of floodplain development occurs.
Biologically productive wetlands are often an intrinsic part
of the floodplain. Wetland areas are characterized by satu-
rated soils, and are usually the lowest lying areas of the
floodplain, found in close proximity to the stream channel.
As a result of natural nutrient cycles and the periodic ex-
change of materials between the river (or estuary) and the
wetland area, wetlands are an important habitat for fish
and wildlife. The decayed organic matter carried by the
flood waters to the river is an important source of nutrients
for fish and wildlife as well.
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Problems associated with flooding often increase as the
floodplain becomes more urbanized. As development occurs,
the area where the water can soak into the ground is de-
creased, and runoff of water from nonporous surfaces increases,
The increased runoff may create greater flooding problems
downstream, as well as downstream pollution problems.
When development occurs in the floodplain, special construc-
tion standards, such as the elevation of the ground floor of
a building, may be necessary in order for the property owner
to be eligible for National Flood Insurance. The building
requirements are designed to protect property against flood
damage, safety, and the public cost of flood disaster relief.
Other land management standards developed and implemented by
federal, state and local governments may direct development
to certain portions of the floodplain (or direct development
outside of the floodplain) and provide protection for sensi-
tive environmental areas.
Despite the basic definition and values of the natural flood-
plain described above, floodplain characteristics vary widely
across the country. Certain floodplains are wet at all
times; other floodplains are dry areas adjacent to intermit-
tent streams. Flooding hazard, in turn, widely varies and
reflects many different natural forces. Environmental re-
sources in floodplains and their relative importance are also
varied.
The diversity in types of floodplains as well as different
community floodplain development histories and needs makes
the development of specific standards and criteria for
floodplain development extremely difficult. This is one
of the basic challenges of floodplain impact assessment
and floodplain management, and is a task that requires
the full involvement of federal, state and local officials.
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D. President Carter's Floodplain Management Executive Order
In May, 1977, President Carter issued Executive Order 11988,
titled "Floodplain Management," which sets forth a new policy
and federal role in floodplain protection. In effect, the
Order calls attention to floodplain protection needs and
specifies a floodplain impact identification process for
use by federal agencies. As stated in the Executive Order,
the provisions give additional support for implementation
of the National Environmental Policy Act of 1968, the
National Flood Insurance Act of 1968, and the Flood Disaster
Protection Act of 1973.
Under the Executive Order, agencies are mandated to "avoid
to the extent possible the long and short term adverse im-
pacts associated with the occupancy and modification of
floodplains and to avoid the direct and indirect support
of floodplain development, whenever there is a practicable
alternative." The Order applies to all federal agencies
which acquire, manage, or dispose of federal lands and
facilities; agencies which undertake, finance, or assist
construction and improvements; and agencies which conduct
activities and programs affecting land use, including plan-
ning, regulation, and licensing activities.
The Executive Order on Floodplain Management cites specific
requirements for federal agency compliance:
An agency must first determine whether the proposed
federal action will occur in the floodplain;
If the action is to occur in the floodplain, the
agency should study alternatives to avoid adverse
effects in the floodplain; and
If no practicable alternative is found, the agency
must take steps to minimize the potential harm to
lives and property as well as to protect the natu-
ral values of the floodplain.
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Specific standards for minimizing harm are not included in
the Executive Order; agency procedures will be used to spell
this out for specific programs and activities. If floodplain
siting is the only practicable alternative, the agency must
prepare and circulate a notice explaining why the action is
proposed to be located in the floodplain.
Federal agencies are in the process of issuing or amending
existing regulations in order to define the means to be
used to encourage nonhazardous use of floodplains. The
Federal Insurance Administration of the U.S. Department of
Housing and Urban Development, the U.S. Water Resources Coun-
cil, and the Council on Environmental Quality are coordinating
implementation of the Order and the provision of assistance
to federal agencies. The U.S. Environmental Protection
Agency will consider the findings from this study when
determining their approach to the Floodplain Management
Executive Order.
E. Previous Studies: Wastewater Treatment Facilities
and Secondary Impacts
Three studies relating to wastewater treatment facilities
and secondary development impacts are reviewed here as
background to the findings from the present study.
The first study, "Interceptor Sewers and Suburban Sprawl:
The Impact of Construction Grants on Residential Land Use",
was completed for the Council on Environmental Quality in
1974. Although the study is four years old and although
program administration approaches used by the U.S. Environ-
mental Protection Agency have evolved since that time, the
study documents useful case studies and itiformation related
to secondary development impacts of interceptor sewers.
The second study, titled "Mitigating Secondary Impacts from
the Wastewater Facilities Program" was prepared by the Office
of Land Use Coordination, U.S. Environmental Protection
Agency, in January, 1977. The study documents approaches
used in seven communities to mitigate secondary impacts
from facility construction.
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The third study is the October, 1976 - March 1977 review
and evaluation of '201' wastewater treatment facility grant
program documents completed by the National Wildlife Federa-
tion. The report summarizes findings from a review of over
i>00 negative declarations, environmental appraisals, and
environmental impact statements from various EPA regional
offices. ^
Major findings from each of these studies are summarized
below as background for the analysis of the floodplain
development pressures case studies recently conducted.
The present research builds upon these previously completed
studies.
!• Interceptor Sewersand Suburban Sprawl
"Interceptor Sewers and Suburban Sprawl: The Impact of Con-
struction Grants on Residential Land Use" was prepared for the
Council on Environmental Quality by Urban Systems Research
and Engineering in 197 4» The basic objective was to
determine the effect of EPA funded projects on residential
development patterns in rapidly growing communities. That
output has implications for floodplain management. If interceptor
sewers have a significant effect on residential development
patterns, it is likely that they also can affect development
in floodplains if EPA and local governments do not restrain
floodplain development through other mechanisms.
Two sources of information were analyzed. First, population
design characteristics and flow characteristics of 52 selected
interceptor sewer projects were analyzed. Excess capacity and
possible land use impacts of each project were reviewed.
In order to identify .further land use implications of the EPA
projects, a selected sample of eight local projects with
particularly high excess capacity and a large proportion
of vacant developable land were examined in detail.
The case studies identified the way in which land use and
related planning considerations entered in the design,
review and approval process of the U.S. Environmental Pro-
tection Agency.
The major findings of the study are as. follows:1
1 Urban Systems Research and Engineering, "Interceptor Sewers
and Suburban Sprawl: The Impact of Construction Grants and
Residential Land Use," Volume I, prepared for the Council of
Environmental Quality, Washington, D.C., 1974, pp. 2-30.
-8-
-------
1. Since housing patterns.are a result of a complex
set of historical, economic, social and politi-
cal interactions, interceptor sewer construction
must be considered as only a contributing rather
than a decisive factor in shaping future residen-
tial land use.
2. Nevertheless, the building of interceptors is an
incentive to development, artd the routing, sizing
and timing of new interceptor construction can be
a valuable tool for guiding residential land use.
In order for this to become effective, however,
land use and sewer planning must be more carefully
coordinated.
3. If the federal government wishes to encourage
careful land use planning and control at the local
level, it can begin by evaluating the extent to
which the current design and approval process for
federally-financed interceptors takes into account
land use implications.
4. Interceptor sewers are often sized with tremendous
excess capacity and designed to serve the ultimate,
highest density population anticipated for large
service areas now containing large tracts of vacant,
developable land.
5. Based upon eight detailed case studies, there is
little evidence that local planning and review
processes include a careful assessment of the
potential adverse secondary impacts of interceptor
construction.
6. Financing procedures at both the local and federal
level may encourage the construction of sewerage
systems tailored to the needs of future developers
rather than the control of pollution problems.
Reflecting the findings, study recommendations emphasize
the need to finance only project costs needed for sewer
capacity for the existing population, the staging of project
design in rapidly growing areas, the use of realistic stand-
ards for per capita flow, improved population forecasting
techniques and procedures, and the consideration of environ-
mental effects of land use induced by the interceptor sewer.
-9-
-------
Since 1974 when the study was published, numerous policy
and program changes have taken place in the '201' Wastewater
Treatment Works Program. All '201' Facility Plans are re-
quired to consider the secondary as well as primary impacts
of the facilities. By providing facilities to serve only a
20-year projected population growth, EPA reduces the poten-
tial impacts of wastewater treatment projects. In some
cases, the projected population for the facility is less
than 20 years.
2. Mitigating Secondary Impacts fromtheWastewater
Facilities Program
In 1977, the EPA Office of Land Use Coordination compiled a
case study analysis of measures actually used to mitigate
secondary impacts from the '201' Wastewater Treatment Works
Program. The study was undertaken in response to the charge
that new regional sewage facilities, in certain cases, were
facilitating rapid population growth which results in adverse
impacts on water quality, among other impacts.
The case studies were undertaken to identify successful miti-
gation measures which could be useful in different parts of
the country. As a second purpose, the studies were under-
taken to sharpen the focus of EPA policy concerning secondary
impacts.
As identified by the study, the major secondary impacts from
the 201 Wastewater Treatment Works Program result from the
placement, sizing, and staging of interceptor sewers and the
provision of reserve capacity in those sewers. Examples of
secondary impacts include:2
Changes in the timing, density, type and location of
development. The provision of public sewage capacity
can affect many aspects of urban development especial-
ly when urban development is not possible without
sewer facilities.
Changes in air, water, noise, solid waste or pesticide
pollution stemming from the induced changes in popu-
lation or land use. The induced changes may inten-
sify the water pollution that the facility was de-
signed to eliminate.
2 Office of Land Use Coordination U.S. Environmental Protection
Agency, "Mitigating Secondary Impacts from the Wastewater
Facilities Program," Washington, D.C., 1975.
-10-
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Damage to sensitive ecosystems, such as wetlands or
wildlife habitats, or culturally important areas as
a result of changes in population and land use.
In order to illustrate approaches used for mitigating second-
ary impacts, seven case studies were detailed.
Types of mitigating measures found in the case studies
included the following:
Project re-design and revision;
Scaling down of original treatment project design
to service a smaller area;
Grant conditioned on not accepting wastewater
from new development in certain locations, or a
certain number of hookups;
Grant conditioned on the completion of certain
technical studies or plan preparation and
implementation; and
Separate facilities for sub-areas built in phases
in lieu of one large regional treatment plant
with a long interceptor.
In all but two of the cases, the first significant point of
EPA involvement in the land use issues occured after the
questions were raised as part of the Environmental Impact
Statement process. In two of the cases, the concerns were
first discussed with the applicant at pre-application con-
ferences.
The case study of the Renner Sanitary District in South
Dakota is of particular interest since it focuses on the
secondary impacts of a collection sewer system on the Big
Sioux River Floodplain, near Sioux Falls, South Dakota.
In the review of the Step 1 Facility Plan, the question
of the impact of sewer connections to serve new floodplain
development (.some lots had already been developed) was raised,
Sewer service to the floodplain was necessary because ground-
water contamination as a result of malfunctioning septic
systems had been identified by the County Department of
Health.
-11-
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Through meetings between EPA and the Minnehaha County Plan-
ning and Zoning Commission, it was determined that EPA would
condition Step II and III grants by prohibiting connections
from any new dwelling within the 100-year floodplain. This
policy reflected the policy of the County to prohibit new
floodplain development.
Mitigating measures used to reduce impacts included (1)
conditions on the Step II grant which required that no con-
nections be allowed for future development within the 100-
year floodplain, and (2) recommendations that the collection
line be sized to serve existing residents plus a "moderate"
amount of new growth.
3. National Wildlife Federation Evaluation
In April, 1977, the National Wildlife Federation published
the third in a series of reviews of environmental documents -
from the '201' Wastewater Treatment Works Program of EPA.3
The research, funded by the Council on Environmental Quality,
has provided for a documentation and assessment of EPA com-
pliance with the 1966 Executive Order on Floodplain Manage-
ment (Executive Order 11296) and an assessment of the degree
to which secondary land use impacts are typically considered
in environmental impact documents.
Through a Freedom of Information request, the National Wild-
life Federation received declarations, appraisals, and en-
vironmental impact statements from EPA Regional Offices. When
environmental appraisals indicated potential adverse environ-
mental impacts, the study team investigated projects in further-
detail. Based upon a review of approximately 500 documents and)
numerous contacts with EPA personnel, state and federal agency
officials, and private conservation groups, findings and re-
commendations for reducing the environmental impact of '201'
wastewater treatment facilities were made.
3 Thomas K. Bick, "Third Interim Review of EPA 201 Wastewater
Treatment Facility Grant Program Documents for Land Use Im-
pacts, NEPA Compliance and Public Participation, October 1,
1977," National Wildlife Federation, Washington, D.C., April,
1977.
-12-
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Major findings and recommendations of the study related
to floodplains impacts and land use impacts are summarized
below.
Floodplain impacts; Executive Order 11296 mandates the
avoidance of the uneconomic, hazardous, or unnecessary
use of floodplains. The major finding from the National
Wildlife Federation's,survey is that the '201' Program
is still subsidizing urban development in flood hazard
areas on a large scale. The study further found that
floodplain impacts are not being adequately identified or
mitigated by Regional Offices of the U.S. Environmental
Protection Agency.
As noted in the report, communities often propose the
construction of wastewater treatment facilities to serve
new'development in floodplains. In many cases, develop-
ment alreadv exists which requires sewering. In other
cases, developments are proposed in floodplains because
of the availability of flat, open land. A third factor
leading to floodplain development is the need to locate
treatment facilities for cost and engineering reasons.
Often treatment plants located in floodplains can take
advantage of gravity flow of wastewater.
Out of 518 projects reviewed during the reporting period,
at least 78, or approximately 13 percent of the projects,
were found to accommodate or induce a significant amount
of new floodplain development. This total does not in-
clude projects designed to serve existing floodplain
development. Additional findings included the following:
Only one EPA Regional Office (Region IV in
Atlanta) systematically contacts the Flood
Insurance Administration to request that special
floodplain rate maps be prepared when it has
been determined that a '201' facility will
accommodate floodplain growth.
-13-
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Although some regions occasionally, mitigate
floodplain impacts by requiring the relocation
of interceptors and treatment plants to loca-
tions outside of floodplains, or by requiring
that a sewer traversing a floodplain be a
force main, such mitigation measures are rare.
None of the documents reviewed disclosed the
use of hookup restrictions in floodplains as
grant conditions.
The National Wildlife Federation has recommended closer
coordination between EPA and the Flood Insurance Admini-
stration of the U.S. Department of Housing and Urban
Development in order to expedite the preparation of
flood rate map preparation in communities where treatment
facilities are being constructed in floodplains.
A second recommendation is that EPA should disclose all
development located in floodplains which will be served
by new '201' facilities as well as all development induced
by the projects.
The final recommendation is the need for EPA .Washington
guidance and direction to ensure that floodplain develop-
ment is not induced by '201' wastewater treatment facility
projects. The use of hookup restrictions as grant
conditions is recommended.
Land Use Impacts; The degree to which secondary
land use impacts are being considered and mitigated by
EPA was an additional point of review. Major findings
from the review of '201' Program documents and contacts
with officials and observers include:
Secondary land use impacts of '201' facilities
are not being adequately disclosed in environ-
mental declarations and appraisals. Most of
the environmental assessments reviewed also
failed to adequately discuss land use impacts.
EPA project reviewers often felt incapable of
thoroughly assessing land use impacts due to
lack of available information, lack of expertise,
or lack of time.
-14-
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Interceptors are regularly designed for 50
year population projections and treatment
plants are designed for 20 year population
projections.
The staging of facility projects in order to
avoid induced growth was proposed in only a
small percentage of the projects reviewed.
In locations where secondary land use impacts
are expected, most EPA Regional Offices are
reluctant to exercise their authority to
control hookups in order to reduce the impacts,
Most EPA Regional Offices question their
legal authority to restrict hookup or impose
land use planning requirements. Regional
Office personnel also feel that hookup
restrictions are not practical, and believe
that EPA cannot enforce such restrictions
after the final construction grant payment
has been made.
Most EPA Regional Offices feel that the miti-
gation of land use impacts from '201' facili-
ty projects is the sole responsibility of
local planning agencies.
The National Wildlife Federation has recommended that
the Washington Office of EPA provide more specific •
guidance to Regional Offices concerning the evaluation
of secondary impacts. Additional information and
regulations concerning grant conditions is also recom-
mended. Iri^response to the issue of facility sizing
and staging, the National Wildlife Federation has
recommended that interceptor sewers be sized to ac-
comodate 25-year population projections,; and that ten-
year staging of facilities should be required when
sewers serve areas which are less than 60 percent
developed.
-15-
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CHAPTER TWO
RESEARCH METHOD AND MAJOR FINDINGS
A. Introduction
The purpose of the research on floodplain development pres-
sures undertaken for the Office of Federal Activities, U.S.
Environmental Protection Agency, has been to document the
impacts of federal programs in selected case study locations
and to recommend program approaches to the '201' Wastewater
Treatment Works Program, based upon the findings.
As a supplement to the case studies/ meetings were held in
three EPA Regional Offices to review current floodplain im-
pact issues related to wastewater treatment facilities.
Floodplain development pressures and impacts of federal pro-
grams were also discussed through telephone contacts with
Regional Offices of the Federal Insurance Administration
located in Denver, Kansas City, and Atlanta.
The assistance of local and federal officials interviewed
is gratefully acknowledged. Although the findings and
recommendations of this study are made by The Research
Group, Inc., many valuable insights and information were ob-
tained through case studies and other meetings.
This chapter is divided into several parts. First, the
basic research method and approach to the case study in-
terviews is presented. Second, the actual findings from
the case studies are documented with appropriate summary
tables. Finally, inter-agency aspects of floodplain man-
agement identified primarily through federal agency con-
tacts are presented.
Case study descriptions are presented in Part III of this
report. The interested reader is urged to review specific
background information and federal program impacts from
each case. Case study maps are presented to orient the
reader to community features and federal programs in Part III,
-16-
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B. Case Study Method
In order to document the impacts of federal programs on
floodplain development, thirty-one case study locations
were selected for detailed local agency interviews. Case
study locations within the jurisdictions of the Atlanta,
Kansas City, and Denver Regional Offices of EPA were se-
lected. Detailed interviews with local planning direct-
ors and other officials provided the basic information.
Case study locations were selected in order to maximize
the potential for obtaining information on wastewater
treatment facility impacts. Due to the relatively small
number of sites to be selected, a random sampling pro-
cedure was not used. Although the results from the case
studies can not be generalized to all communities re-
ceiving wastewater treatment facilities, the information
obtained has important implications for the implemen-
tation of floodplain development impact policies by the
U.S. Environmental Protection Agency.
The following criteria were used to select case study
locations:
Locations where a '201' Wastewater Treatment
Works construction grant involving both a
treatment plant and interceptor had been
received;
Communities which received grants early in
the 1970's, in order to maximize the poten-
tial of secondary development impacts; and
Communities which were located in or near
different types of floodplains and which
had different types of development pressures.
In order to maximize the diversity of the case studies,
efforts were make to select locations with different economic
social, and physical characteristics. For example, in
the Southeast, an effort was made to survey several com-
munities in low-lying coastal areas, as well as areas in
the rolling Piedmont area. In the Midwest, communities
near major rivers as well as small streams were surveyed.
In some cases, communities were entirely in the floodplain
while in other cases, only a portion of the town was in
the floodplain.
-17-
-------
It was recognized that if a community was not experienc-
ing growth and development, the construction of treatment
facilities would probably not be found to be a contribu-
tor to growth. Therefore, it was hoped that small, no-
growth rural communities could be avoided. It was found,
however, that in order to meet the first two criteria listed
above, a number of small communities needed to be
included in the survey. Most large cities have not had
initial wastewater treatment plant and interceptor con-
struction through the '201' Program. As a result, the
findings from the study concerning impacts of treatment
facilities are conservative and understate potential
impacts of treatment facilities. Case study locations
are shown on Figures 1, 2, and 3.
Interviews with local planning directors and other offi-
cials were completed in each of the case study locations.
During the meetings, the following questions were review-
ed.
1. What are the boundaries of the 100-year flood-
plain near the '201' wastewater treatment facil-
ity?
2. Over what period of time has development in
the floodplain occurred? When did most of the
development occur? Is the floodplain completely
developed at present?
3. What federal programs or projects (including
planning and construction activities) have
taken .place in the selected floodplain?
4. When were the federal programs or projects
initiated and completed?
5. To what extent have these federal programs and
projects influenced development in the flood-
plain?
In cases where there was significant development in the
floodplain, the floodplain area within the facility ser-
vice area was used as the study area boundary. In cases
where floodplain development was insignificant, the en-
tire service area of the facility or the entire community
was used.
-18-
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FIGURE 1
CASE STUDY LOCATIONS - ATLANTA REGION
KEY;
1- Fulton County, Ga.
2- Macon and Bibb County, Ga .
3- Perry, Ga.
4- North Macon County, Ala.
5- North Myrtle Beach, S-C.
-19-
6- Sumter, S.C.
7- Columbia, S.C.
8- Batesburg and Leesville,
S .C.
9- Tybee Island, Ga.
10- Buford and Sugar Hill,
Ga.
-------
FIGURE 2
CASE STUDY LOCATIONS - KANSAS CITY REGION
KEY;
1- York, Nebraska
2- Manhattan, Kansas
3- DeSoto, Kansas
4- Wamego, Kansas
5- Pleasant Hill, Missouri
6- Harlan, Iowa
7- Omaha, Nebraska
8- Davenport, Iowa
9- Council Bluffs, Iowa
10- North Kansas City,
Missouri
-20-
-------
FIGURE 3
CASE STUDY LOCATIONS - DENVER REGION
MONTANA
WYOMING
i *
1
*
1
1
i
r —
i
i."
1
3 2!
UTAH
NOOTH DAKOTA
SOUTH DAKOTA
10
COLORADO
KEY;
1- Rock Springs, Wyoming
2- Hyrum, Utah
3- Wellsville, Utah
4- Missoula, Montana
5- Grand'Junction, Colorado
6- DeSmet, South Dakota
7- Howard, South Dakota
8- Keystone, South Dakota
9- Monroe, South Dakota
10- Wasta, South Dakota
11- Rapid Gity, South Dakota
-21-
-------
In all case studies, an effort was made to completely document
the types of federal programs occurring and tfie effect of
the federal programs on floodplain development. A detailed
analysis of the causes of development pressures apart from
federal programs was not made, although observations of
planning directors were recorded. In order to insure that
a wide range of federal programs were discussed, the list
displayed on Figure 4 was used during the course of the
interviews.
C>, Federal Programs and Floodplain Development Impacts
The thirty-one case studies of local communities and flood-
plain development pressures document the timing of federal
agency programs and activities and the relationship of
federal programs to floodplain development. Figures 7 through
12 summarize the finding from the case studies in each of
the three regions. Two figures pertain to each region where
case studies were conducted, as follows;
Figures 5, 6* and 7:
Figures 8 » 9 ,
and
Locational characteristics of
the case studies, including the
type of community surveyed, the
type of floodplain, the type of
study area selected, and the use
of the floodplain (such as developH
ment and open space uses). Figure
7 pertains to case studies in the
Atlanta region, Figure 8 pertains
to the Kansas City region, and
Figure 9 pertains to the Denver
region.
Effect of selected Federal pro-
grams on floodplain development
and community development.
Figure 10 pertains to case studies
in the Atlanta region, Figure 11
pertains to the Kansas City region,
and Figure 12 pertains to the Den-
ver region.
-22-
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As documented on the "locational characteristics" charts,
the communities surveyed reflect a wide variety of situa-
'tions. Some communities were rapidly developing while
others exhibited slow growth rates. In several cases, the
question was not "how do federal programs affect develop-
ment" but, rather, "how do federal programs assist commun-
ities in adjusting to population losses," reflecting the
lack of. urban development.
The types of floodplains found in the case study communi-
ties also were highly varied. In the Southeast, types of
floodplains included intermittent streams, extensive
bottomland hardwood swamps, smaller swamps, and low-lying
coastal floodplains. In the Midwest, both major riverine
floodplains and small creek floodplains were encountered.
In the West, creek floodplains, high watertables, several
intermittent streams, and one major riverine floodplain
were included in the case study communities.
Although the diversity of floodplain types reflects the
varying conditions in these three regions, the sample of
case studies does not reflect the geographic distribution
of types of floodplains. For example, extensive river
swamp forests are found adjacent to many of the
major rivers in the Southeast and represent important wet-
land and floodplain resources. Only one case study com-
munity. ..North Macon County, Alabama...has a floodplain
which can be characterized as an extensive swamp.
A complete listing of the number of communities in the
Southeast, West, and Midwest where significant development
in floodplains presently exists has not been compiled, al-
though the basic information is available from Regional
Offices of the Federal insurance Administration. Only six
of the 31 case study areas (less than one-fifth of the
total) experienced enough floodplain development to justify
using the floodplain alone as the case study boundary. It
is believed, however, that the basic observation that many
communities do not have significant development in flood-
plains is accurate. Natural features such as steep slopes,
wet soils, and frequent flooding tend to restrain develop-
ment in many floodplains. In each of the regions included
in the study, however, there are communities where flood-
plain development problems are severe.
•23-
-------
FIGURE 4
FEDEHAL PROGRAMS WITH
POTENTIAL FLOODPIAIN IMPACTS
*The following list of programs was used during case study interviews
PROGRAM OR PROJECT
Haste Treatment Facilities Program
Sewer and Water Facilities Program
Public Works Program
Coastal Energy Impact Program
Federal Aid Highway Program
AGENCY
U.S. Environmental Protection Agency
Fanners Home Administration, U.S.
Department of Agriculture
Economic Development Administration,
U.S. Department of Commerce
Office of Coastal Zone Management,
U.S. Department of Commerce
Federal Highway Administration,
U.S. Department of Transportation
Urban Mass Transit Program
Community Development Block Grant
Program
Flood Control Projects (Dams,
Reservoirs, channels, Levees)
Watershed Protection and Flood
prevention Program (Channels and
Dikes)
Public Works Projects
(Dams and Reservoirs)
Public Works Projects
(Dams and Reservoirs)
Federal Housing Assistance and
Mortgage Programs
Coastal Zone Management Program
'208 * Areawide Water Quality
Management Program
'701' Comprehensive Planning
Assistance Program
Urban Studies Program
'404' Wetlands Permit Program
National Pollutant Discharge
Eliminiation System (NPDES) Permit
Program
National Flood Insurance Program
National Environmental Policy Act
Urban Mass Transit Administration,
U.S. Department of Transportation
Office of Community Planning and
Development, U.S. Department of
Housing and Urban Development
U.S. Army Corps of Engineers
Soil Conservation Service, U.S.
Department of Agriculture
Tennessee Valley Authority
Bureau of Reclamation, U.S.
Department of the Interior
U.S. Department of Housing and
Urban Development
Office of Coastal Zone Management,
U.S. Department of commerce
U.S. Environmental Protection
Agency
U.S. Department of Housing and
Urban Development
U.S. Army Corps of Engineers
U.S. Army Corps of Engineers
U.S. Environmental Protection Agency
Federal Insurance Administration,
U.S. Department of Housing and
Urban Development
Council on Environmental Quality
-24-
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to
Ul
Tybee Island,
Georgia
X
X
x
x
X
X
Buford & Sugar
Hill, Georgia
x
X
X
X
X
X
Morning Creek
Basin, Fulton Co.,
Georaia
X
X
X
X
X
North Macon Co . ,
Alabanta
X
X
X
X
X
X
Horth Myrtle Beach
S.C.
X
X
X
Rocky Creek &
Tobosofkee Ck.
Basins, Macon, Ga.
X
X
X
X
^< .
Perry, Georgia
X
X
X
X
X
X
Pocataligo 'River
Basin, Sumter, S.C
X
X
X
X
X
X
^s
Batesburg
Leesville, S.C.
X
X
X
X
X
Mill Creek Basin,
Columbia, S.C.
X
X
X
X
f CO O ./f
O tt PI / O
oca /no
po.ro / er o
It << / It U ft
H- / H- d H-
O / (1 tt O
» / ana
O / ft
/ a
/ K
/ H-
/ •
/ i
TYPE OF COMMUNITY
1. Small town - no
growth
2. Small town - moder-
ate growth
3. Small town - rapid
growth
4. Metropolitan area -
no orowth
5. Metropolitan area -
moder atf^ rj*-r»wi"li
>. Metropolitan area -
rapid qrowth
TYPE OP FLOODPLAIN
L. Extensive bottomland
hardwood swanro
I . Small swamp or area
with drainage problems
i. Low-lying coastal
f loodplain
ffiYPE OF STUDY AREA
L. City - Major portion
:. Drainage Basin
3. Floodplain Only
I. Service area of
treatment: plant
••LOODPLAIN USES
L. Urban development
! . Open space/Park
3. Agriculture
1. Undeveloped
HI
n
a
3
Ul,
-------
to
North
Kansas City, Kansas
!
X
X
X
X
X
X
X
Council Bluffs, Iowa
X
X
X
w
X
Davenport, Iowa
X
M
X
X
X "
X
Omaha, Nebraska
X
X
X
— x ~
X
~~5T"
X
Harlan, Iowa
X
X
•^
X
Pleasant Hill,
Missouri
X
X
X
X
X
X
S
10
X
X
X
X
X
M
DeSoto, Kansas '
X
X
X
X
X
X
Manhattan, Kansas
X
X
X
X
X
X
M
X
X
York, Nebraska
X
X
X
X
X
,,„
nt /
r /
S /*
/ f>
/ oS
/ ffffff
/ M M s
/ H- HI
/ wo
/ ft 1
/ H-
/ O
/ a
TYPE OF COMMUNITY
1. Small town - no growth
<2. small town - moderate
growth
3. Small town - rapid
growth
4. Metropolitan area -
no growth
b. Metropolitan area -
moderate growth
6. Metropolitan area -
rapid growth
TYPE OF FLOODPLAIN
1. Major riverine
floodplain
2. Small creek with
flooding
3. High water table
4. Intermittent stream
TYPE OF STUDY AREA
1. City - major portion
2. Drainage basin
j. Flood plain only
4. Service area of
treatment plant
FLOODPLAIN USES
1. Urban development
2. Open sjjace^gark
3. Agriculture
4. Ond«v«lop«J
H
O
C
»
w
-------
FIGURE 7
DENVER REGION - LOCATION CHARACTERISTICS
^w
\. Location
\Charac-
\^ teristics
Case >v
Study \
Locations \^
Hock Springs ,
Wyoming
Hyrum, Utah
(Little Bear River)
Wellsville, Utah
(Little Bear River)
Missoula, Montana
Grand Junction,
Colorado
DeSmet, South Dakota
Howard, South Dakota
Keystone, South
Dakota
Monroe, South Dakota
Wasta, South Dakota
Rapid City, South
Dakota
OF COMMUNITy
w
&
5j?;
g
^
0*
g
i
i-i
•-I
i
O]
H
X
X
X
X
x
id
4)
I
fl|
CM
0
•H
Small town - raf
growth
•n
X
X
X
1
id
§5
HI O
s e
w
(
•d
Metropolitan are
moderate growth
in
X
X
•d
Metropolitan are
rapid growth
VO
Z
M
&
pi
^
_
Major riverine
floodplain
H
X
Creek with
flooding
n*
X
X
X
; l ix
X
X
i
S
§
3
-------
FIGURE 8
ATLANTA REGION - EFFECT OF FEDERAL
PROGRAMS ON DEVELOPMENT
\Federal
>v Programs
Case \
Study \
Locations \^
Kill Creek
Basin,
Columbia, S. C.
Batesburg s
Leesville, S. C.
Pocataligo
River Basin,
Sumter, S. C.
Perry, Ga.
Rocky Creek £
Tobosofkee
Ck. Basins,
Macon, Ga.
North Myrtle
Beach, S. C.
North Macon
Co., Alabama
Morning Creek
Basin, Fulton
Co., Ga.
Buford £
Sugar Hill, Ga.
Tybee Island,
Georgia
8 .
•P X
m
•201* Has
Treatment
Program -
o
o-a-d
o-e-d
•
o-a-d
o
o-a-d ;
o-a-d
o-a-d
o
•ft
= 5
•0 &
Federal-A
Program -
o-e-d
o
o-a-d
o
o
o-a-d
o-e-d
a e
i S
r4 0
01 M
«;
Community
Block Gra
HUD
o
°
o-e-d
0
s
1
h
-------
FIGURE 9.
KANSAS CITY REGION - EFFECT OF FEDERAL
PROGRAMS ON DEVELOPMENT
\. Federal
\Programs
Case >v
Study \^
Locations \*
York, Nebraska
Manhattan, Kansas
DeSoto, Kansas
Waaiego, Kansas
Pleasant Hill,
Missouri
Harlan, Iowa
Omaha, Nebraska
Davenport, Iowa
Council Bluffs,
Iowa
Kansas City,
Kansas
'201* Wastewater
Treatment tiorks
Program - BAP
o-e-d
o-a-d
o-a-d
(future)
o-a-d
o-a-d
o
o-e-d
0
o-e-d
o-a-d
!
Federal-Aid Highw
Program - DOT
0
o
o-e-d
(future)
o-a-d
0
o
o
o-e-d
•U 1
Community Develop
Block Grant Progr
HUD
o
i
«
Other Sewer and W
Programs
National Flood
Insurance Program
HUD
o
o-d-f
o
o
o-d-f
o-d-f
(future)
o-d-f
o
I
UJ
I
CU [E]
o-e-d
9
8i
Low and Hoderate
Housing Programs
o
o
o
Land and Nater
Conservation Fund
HCRS
o-d-f
o-d-f
?
1 tt
to
-------
FIGURE 10
DENVER REGION - EFFECT OF FEDERAL
PROGRAMS ON DEVELOPMENT
\
\ Federal
\ Programs
\*
Case >v
Study \.
Locations ^\
Rock Springs,
Wyoming
Hyrum, Utah
(Little Bear River)
Wellsville, Utah '
(Little Bear River)
Missoula, Montana
Grand Junction,
Colorado
DeSmet, South
Dakota
Keystone, South
Dakota
Monroe, South
Dakota
Wasta, South
Dakota
Rapid City,
South Dakota
u a
11 10 O<
*j ,* -^
n M i ctf i
f 1 2 *• jj
«-« « & V tjf
o a o u o
" £ a £ ft
o-a-f 0
o-e-d
o-a-d :
o-a-d I °
0 I 0
o-e-d !
(if !
annexa- >
tion
occurs) :
o-a-f
]
o-a-d
!
0 0
4— ....._....„ .,.
0 0
•U 1
§ s
h
4> h
s°-
QS
IL
u OQ S
o
o-e-d
o-a-d
0
B
£
1
4
U
Other Sew
Programs
o
0
i
§
k
£"•
National
Insurance
HUD
o
,
i
2
cu
01
U
OU U
0
0
0
0
So
fl
0) n
tia
0) CP
Q 2
£ cu
fl C
(0 -4
ll
o
0
o
1
1
U h
*J C
4J
*O 01 W
c c S
0
0
o
o-p-f
o-p-f
h
+J $
i-> 0>
o c
H U
« 0
U 0}
SJ
JE
0. <
o-a-f
o
0) i
c Z
o a
« "n
•701' Com
Planning
HUD
KEY:
o - program occurred
e = encourage
a » allow
d - discourage
o-e-f means that the program
occurred and encouraged development
in the floodplain
o-a-d means that the program occurred and allowed development
(excluding floodplain) outside of the floodplain.
-30-
-------
FIGURE 11
EFFECTS OF FEDERAL PROGRAMS ON SECONDARY DEVELOPMENT:
SUMMARY OF CASE STUDIES
^v Federal
^S. Program
\
Number of Cases >^
Program Occurred
Program had no
effect on
development
Program encouraged
community developmment
Program encouraged
floodplain development
Program allowed
community development
Program allowed
floodplain development
Program discouraged
community development
Program discouraged
floodplain development
i
'201 Wastewater
Treatment Works
EPA
31
9
6
0
14
2
0
0
1
Federal-Aid
Highway Program
DOT
23
16
4
0
3
0
0
0
Community
Development
Block Grant
Program-HUD
9
8
1
0
0 •
0
0
0
111
u 8 fe
ta o<
-------
Figures S, 9, and 10 indicate the major federal programs
affecting development in the case studies in each region.
Figure 11 summarizes the findings for federal planning and
construction programs which occurred in 8 or more case
study locations. Detailed information for each case study
is included in Part II of this report.
When reviewing the information from the cases, it should
be remembered that the study area included both floodplain
and non-floodplain lands in all but six cases. As a result,
more information was obtained on the impact of federal pro-
grams on general community development than specific effects
on floodplain development. Cases where little or no
floodplain development was present reflected the natural
conditions or local government regulations which restricted
development.
If only communities with floodplain development had been
included as case studies, it is believed that similar find-
ings concerning the effect of federal programs would have
been observed. Many of the types of pressures leading
to floodplain development are the same as the pressures
leading to upland development.
The following programs were most frequently encountered
in the 31 case studies and, therefore, have been tabulated
on Figures 8, 9, and 10:
'201' Wastewater Treatment Works Program -
U.S. Environmental Protection Agency;
Federal-Aid Highway Program - U.S. Depart-
ment of Transportation;
Community Development Block Grant Program -
U.S. Department of Housing and Urban De-
velopment;
Other federal agency sewer and water pro-
grams, including the Sewer and Water Facil-
ity Loan and Grant Program of the Farmers
Home Administration, U.S. Department of
Agriculture, and Sewer and Water Loans and
Grants from the U.S. Department of Housing
and Urban Development;
National Flood Insurance Program - U.S.
Department of Housing and Urban Develop-
ment;
-32-
-------
Public Works Program - Economic Develop-
ment Administration;
Low and Moderate Income Housing Programs
(not including mortgage insurance) - U.S.
Department of Housing and Urban Development;
Land and Water Conservation Fund Program -
Heritage Conservation and Recreation Service,
U.S. Department of the Interior (formerly
the Bureau of Outdoor Recreation);
Public Works Projects - U.S. Army Corps of
Engineers; and
'701' Comprehensive Planning Assistance Pro-
gram - U.S. Department of Housing and Urban
Development.
Background information about the legal authority, purpose
and direction for these federal programs is included in
Part II of this study titled "Methods Used by Federal Pro-
grams to Reduce Floodplain Development Pressures." The
specific nature of the federal programs in each case study
is described in Part III of this study.
Certain other federal programs were found to be carried out
in the majority of communities surveyed. These programs
include:
National Pollutant Discharge Elimination System
Permit Program (NPDES) - U.S. Environmental
Protection Agency;
'404' Permit Program - U.S. Army Corps of
Engineers;
Mortgage insurance programs - Farmers Home
Administration, U.S. Department of Agriculture,
and the Federal Housing Administration, U.S.
Department of Housing and Urban Development;
and
-33-
-------
'208' Areawide Water Quality Management Program -
U.S. Environmental Protection Agency.
Although these programs frequently occur, they were found
in the case study communities to have little effect on
floodplain protection or development and, therefore,
are not listed on the summary charts.
The number and type of federal programs in effect in each
case study community varied significantly. In some case.
study locations, nearly every federal program had occurred.
In other cases only the '201' Wastewater Treatment Works
Program and perhaps one or two other programs had taken
place. A complete listing of the federal programs noted
by the persons interviewed is contained in the case
study summaries (Part III).
The charts shown on Figures 8, 9,10> and 11 indicate whether
the program was used in the case study area and also indi-
cate the effect of the program on development, as identi-
fied by the persons interviewed. In some cases, the fed-
eral program affected development in the floodplain while
in other cases, development in the entire case study area
was affected. Some programs were found to encourage de-
velopment while others allow development to take place.
Several programs discourage development in the floodplain.
Very few federal programs were found to encourage or allow
urban development, either in the floodplain or the entire
case study area. Many persons interviewed observed that
federal programs helped to improve the attractiveness of
the community and the "liveability" of communities. Typic-
ally, the primary forces encouraging growth and development
were private industries or major institutions which pro-
vided jobs and stimulated in-migration. Many federal pro-
grams have been necessitated by population growth and de-
velopment. Exceptions to this statement are federal agen-
cies which purchase land and provide major employment bases
and the three federal programs reviewed below.
-34-
-------
Three federal programs were found to either encourage or
al'low development in a number of case study locations.
These programs include:
'201' Wastewater Treatment Works Program, U.S.
Environmental Protection Agency;
Public Works Program (individually authorized
through Congressional resolutions), U.S. Army
Corps of Engineers; and
Federal-Aid Highway Program, U.S. Department
of Transportation.
Particular findings concerning each of the federal pro-
grams are presented below.
'201' Wastewater Treatment Works Program, U.S.
Environmental Protection Agency;
The impact of wastewater treatment facility construc-
tion on development is affected by the type and
location of the facilities, growth and development
patterns in the community, soil types, and local
government regulations pertaining to public facili-
ties, among other factors. The predominant effect
of the Program noted in the case studies is that it
allows development to occur.
Out of 31 case studies where '201' wastewater treat-
ment facilities were being planned and constructed,
a total of 16, or approximately 50 percent, allowed
urban development to take place. Often the facili-
ties (especially interceptor lines) had the effect
of permitting higher densities of development and
directing development to certain locations in the
community.
-35-
-------
In 6 of the 31 cases, the '201' Wastewater Treatment
Works Program encouraged development. This
finding primarily applies to two situations: (1)
situations where small communities require sewer fa-
cilities to be attractive places for new industry; and
(2) situations where development on septic tanks is
difficult or prohibited, and where sewer facilities
are a pre-requisite for any development.
In 9 of the 31 cases, the '201' Wastewater Treatment
Works Program had no impact on growth and development.
In some, cases, the '201' program facilities were an
extension or expansion of present facilities and not
of a significant magnitude to stimulate development.
In other cases it was clearly stated by officials
that development could easily occur on septic tanks
or small package treatment plants and that the
treatment facilities did not influence development
although they were a community amenity.
Because of the approach to the selection of the
case study locations, very few of the '201' projects
reviewed were for large, regional treatment facili-
ties serving two or more municipalities and large
unincorporated'areas. In order to obtain information
from communities where '201' facilities were far along
with planning or under construction, projects completed
prior to 1977 were reviewed whenever possible . It is
suspected that a survey of opinions concerning poten-
tial impacts of large, regional wastewater treatment
projects would result in a higher percentage of re-
sponses that the facilities allow development to occur.
Almost every person interviewed had very clear and defi-
nite views concerning the effect of '201' facilities
on urban development. This fact, combined with the
geographic distribution of the facilities which were
found to affect development, suggest that certain
geographic areas can be delineated where development
impacts from the provision of sewer facilities are
most likely to occur. Areas where development pres-
sures exist and where soils prohibit septic tanks are
likely to experience greater development impacts from
the '201' Program.
-36-
-------
Development impacts from other sewer and water programs
funded by the U.S. Department of Housing and Urban,
Development and by the Farmers Home Administration
of the U.S. Department of Agriculture was expected
to vary from the '201' Wastewater Treatment Works
Program because they often provide funds for collector
sewer lines rather than for interceptor construction.
The collector sewer lines are often small projects
and are often extended to homes and businesses either
during or after development has actually taken place.
The construction of wastewater treatment plants and
major interceptor sewers, are more likely to have
secondary development impacts than collector sewer
.lines.
Public Works Projects, U.S. Army Corps of Engineers;
Out of 9 communities where public works projects
constructed by the U.S. Army Corps of Engineers
were reported, 6 projects resulted in some type
of development impact. All projects where impacts
were reported involved the construction of dikes
or levees for flood protection.
Levee and dike construction has often been carried
out in locations where flooding occurs regularly
and creates high hazard conditions, endangering
lives and property. Without structural protection
from floods, development could not take place since
it would be subject to destruction on a frequent
basis. In such cases, the construction of the levee
or dike actually changes the location of the flood-
plain for purposes of floodplain management. Although
the "natural" floodplain is in the same location, the
area of high hazards where special regulations or
development control programs may be needed is altered.
The degree to which the structure actually affects
;flood hazards, of course, affect the location of the
100-year floodplain.
-37-
-------
The primary effect of levee construction in the
cases surveyed is that the structure allows
development to occur. In Davenport, Iowa, if
a levee is actually constructed along the
Mississippi River (plans have been completed),
planners believe that the project will actually
stimulate or encourage development.
In Missoula, Montana, the construction of a major
dike along the Clark Fork River has allowed some
floodplain development to occur. This is largely
because the precise boundaries of the floodplain
were not known when the project was constructed
between 1970 and 1975. Now that floodplain
boundaries have been properly delineated, the
project is only allowing development outside of
the floodplain to occur.
Federal-Aid Highway Program, U.S. Department of
Transportation;
The Federal-Aid Highway Program was frequently
reported in the case study communities (23 times
out of 31 cases). Projects reported included
Interstate highway construction, major U.S.
highway construction, and smaller road repair
projects. Because of the variety of types of
highway projects, the survey results must be
cautiously reviewed.
In seven of the 23 instances where the Federal-Aid
Highway Program occurred, the Program either en-
couraged or allowed development to take place.
Most of the communities where the Program has
affected development are suburban or outlying
areas within commuting distance of major metro-
politan areas. The construction of a major
highway or Interstate, in these cases, provides
important access to jobs and commercial centers
and is a positive force encouraging or allowing
development to occur. In the Rocky Creek and
Tobosofkee Creek Basin case study (Macon,
Georgia), the construction of an Interstate
highway combined with the construction of a
major sewer interceptor has allowed urban de-
velopment to take place.
-38-
-------
Although community development impacts from the '201' Waste-
water Treatment Works Program, the Federal-Aid Highway Pro-
gram, and the Public Works Program of the U.S. Army Corps
of Engineers were observed most frequently in the case
studies, it is believed that almost all federal programs
have impacts on growth and development in certain cases.
Because of the small number of case studies, major de-
velopment impacts from certain federal programs were not
recorded. However, sewer interceptors and treatment
plants, major highways, and the construction of Hikes
and levees in flood-prone areas have potential development
impacts which tend to occur more frequently.
The impact of federally-owned facilities or installations,
such as air force bases, on community growth and development
was noted in several case studies. Federal facilities that
provide local employment are potential stimulators of flood-
plain development.
Although no single federal program provides specifically
for the planning or regulation of comprehensive floodplain
management at the local level, two federal programs were
found to have significant impacts on floodplain development
control. These programs, which were noted by officials
interviewed as being factors which discourage floodplain
development, include the National Flood Insurance Program
administered by the Federal Insurance Administration of
the U.S. Department of Housing and Urban Development and
the Land and Water Conservation Fund Program of the Heritage
Conservation and Recreation Service U.S. Department of the
Interior (formerly the Bureau of Outdoor Recreation), The
effects observed from each of these programs are summarized
below.
National Flood Insurance Program, U.S. Department
of Housing and Urban Development;
Many of the communities included in the case
studies have been accepted into the National
Flood Insurance Program or are in the process
of being accepted. The Program is clearly
providing needed information to local communi-
ties concerning the location of floodplain
boundaries and in a number of cases, is pro-
viding a vehicle for community education
-39-
-------
concerning floodplain management.1
Of the 17 communities which reported that they
are now participating in the National Flood
Insurance Program, 10 indicated that the Pro-
gram has no effect on development while 7 indi-
cated that the Program has discouraged floodplain
development. Persons from areas where development
was located in floodplains almost always noted
that the program was discouraging development.
The only exceptions are locations where local of-
ficials feel that local government regulations
adopted prior to the federal program have provided
the necessary floodplain guidance. The ten commun-
ities which noted that the Program has not affected
development are primarily areas where floodplain
development has not occurred.
It is recognized that the National Flood Insurance
Program is multi-faceted, including technical flood-
plain studies, requirements for flood insurance, and
requirements for local government regulations for
flood hazard protection. Officials interviewed em-
phasized that the local government regulations were
the aspect of the National Flood Insurance Program
which is discouraging growth and development.
The regulations require flood-proofing and
the elevation of structures, and they often
have the effect of encouraging development to
take place in areas outside of floodplains.
Land and Water Conservation Fund Program, U.S.
Department of the Interior
The Land and Water Conservation Program, adminis-
tered by the Heritage Conservation and Recreation
Service of the U.S. Department of the Interior
(formerly the Bureau of Outdoor Recreation), pro-
vides funds for the acquisition and development
of park and recreation areas. Twelve of the 31
cases reviewed in this study have received funds
1 According to officials in the Atlanta, Kansas City, and
Denver Regional Offices of the Federal Insurance Administra-
tion, efforts are made to make local communities aware of
comprehensive floodplain management needs and approaches,
as well as the specific requirements of the National Flood
Insurance Program for flood hazard protection.
-40-
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through the Program. In four of those cases
(one-third of all cases where the Land and
Water Conservation Fund Program was being used)
the Program was found to significantly discourage
floodplain development. In three cases, the funds
were used to acquire floodplain lands for public
park and recreation areas. In the cases of York,
Nebraska; Davenport, Iowa; and Rapid City, South
Dakota., the Program has been an important
floodplain management tool for local govern-
ments .
In 1978, President Carter announced the National
Heritage Trust Program, which will encompass the
Land and Water Conservation Fund Program. Although
Program details are presently being developed,
the Program will continue to provide funds for
park and open space acquisition and development in
floodplain areas.2
In one of the case studies...Rapid City, South Dakota...
federal program efforts to assist with flood damage clean-
up and future floodplain management were documented. It
is significant to note that the Urban Renewal Program of
the U.S. Department of Housing and Urban Development pro-
vided major funding for land acquisition and clearance
following the devastating flood of 1972. Other federal pro-
grams provided repair funds Which were primarily used in areas
outside of the critical 100-year floodplain. The Land and
Water Conservation Fund Program provided funds for park-
land acquisition in the floodplain. Because of the unique
timing and serious effects of the Rapid City flood, federal
program efforts were particularly significant.
In summary, the major findings from the case studies con-
cerning federal programs and secondary development impacts
include the following:
1. Three federal programs ....the '201* Waste-
water Treatment Works Program, (U.S. Environmental
Protection Agency), the Public Works Program (U.S.
Army Corps of Engineers) and the Federal-Aid
Highway Program (U.S. Department of Transporation)
2 Telephone interview with Mr. Paul Pritchard, Assistant
Director, Heritage Conservation and Recreation Service,
U.S. Department of the Interior, May 11, 1978.
-41-
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were found to affect secondary development in a
significant number of case study locations. The
predominant impact identified is that these pro-
grams allow development to occur.
2. Only six of the case studies reviewed had sig-
nificant development in the floodplain. The
predominant reason for the lack of floodplain
development in the case study locations was
natural features which made development diffi-
cult and uneconomical. Few federal programs
in these six communities allowed or encouraged
floodplain development. This fact leads to the
finding that floodplain development pressures
exist in only a segment of the communities
receiving federal funds. In many cases it
is possible to identify in advance the communi-
ties where advance floodplain impacts are likely
to occur.
3. Two federal programs/ the National Flood In-
surance Program and the Land and Water Conser-
vation Fund Program,- were found to discourage
floodplain development. The National Flood
Insurance Program requires local government
flood hazard regulations as a pre-requisite
for eligibility for flood insurance. The Land
and Water Conservation Fund Program protects
floodplains by providing funds for the acquisi-
tion and development of parklands.
D. Present Approaches to the Reduction of Floodplain
Development Pressures
During the course of the study, meetings with EPA Regional
Offices were conducted to discuss present approaches used
for reducing floodplain development pressures. During the
meetings, it was noted that informal coordination with the
Federal Insurance Administration typically occurs when
floodplain development issues related to wastewater treat-
ment facilities are identified. For this reason, tele-
phone contacts with the FIA Regional Offices in Kansas
City, Denver, and Atlanta were also made. The following
observations summarizes findings from the EPA meetings and
FIA telephone contacts:
-42-
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EPA Regional Offices noted that questions
concerning floodplain development impacts
are examined on a case-by-case basis.
Typically the potential for floodplain de-
velopment impacts is identified by the EPA
Regional Office when the environmental
review is conducted and after the
Step 1 Facility Plan has been completed.
Grant conditions which restrict hookups in
floodplain areas are sometimes used as a method
for reducing floodplain development impacts. Many
EPA Regional Office personnel question whether grant
conditions can be enforced after final payment on
the '201' grant has been made.
Other mitigation measures, such as the re-
location or redesign of a facility are also
used by EPA Regional Offices although they
are more difficult to implement. Project
delays often occur because the floodplain
development issue is not identified until
after the Step 1 Facility Plan has been com-
pleted.
Major floodplain development questions and
issues have arisen .for only a small number
of '201' Wastewater Treatment Facility pro-
jects. When issues do arise, discussions and
coordination with the Federal Insurance
Administration often occur. When the
Floodplains Management Executive Order
(No. 11988) is fully implemented, closer
coordination procedures may be established,
since FIA is charged in the Order as the
primary federal source of floodplain in-
formation. At present, formalized pro-
cedures for coordination do not exist.
Two types of Information are available from
the Federal Insurance Aministration which
can be extremely useful in planning waste-
water treatment facilities which are com-
patible with floodplains. First, FIA's
Flood Hazard Boundary maps provide data for
nearly all communities in each state. These
maps are generalized and not normally based
on a detailed analysis of the floodplain.
-43-
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In the process of discussing floodplain development and
impact questions related to wastewater treatment facilities,
background information concerning two *201' wastewater treat-
ment works grants which have resulted in floodplain impact
questions and issues was collected. The Riverside Lakes,
Nebraska project is a useful example of steps taken by the
regional planning agency in the area and the Kansas City
EPA Office to reduce floodplain impacts. The Mississippi
project illustrates the involvement of FIA and EPA in a
case where the wastewater treatment facilities were found
to have adverse impacts on the floodplain. Although secondary
development impacts were not the primary concern, this second
example illustrates the cooperation of FIA and EPA in a
floodplain impact issue.
The specific situation, actions, and implications for each
of these illustrations are described below.
1. Riverside Lakes Project,Nebraska1;
Located 10 miles west of Omaha, Nebraska, "Riverside Lakes"
is the area serviced by Sanitary Improvement District
No. 177 of Douglas County, Nebraska. The District presently
operates a wastewater treatment facility and has applied
to the U.S. Environmental Protection Agency (Kansas City
Office) for funds to expand the facility. The District has
been seeking construction funding since 1971.
The area to be served by the expanded treatment plant is
located on the alluvial plain adjacent to the Elkhorn River.
The terrain is low and flat and subject to flooding.
Present residential development, however, is elevated on
fill, with first floor elevations approximately 5 feet
above the 100-year flood level.
Information on the Riverside Lakes Project was provided
by Mr. Wayne Wiley, Environmental Planner, Metropolitan Area
Planning Agency, Omaha, Nebraska and Mr. Thomas Robertson,
Project Engineer, Kansas City Office, U.S. Environmental
Protection Agency.
-44-
-------
The potential for adverse floodplain development impacts
was first noted by the Metropolitan Area Planning Agency
(MAPA), a multi-jurisdictional planning council composed
of local officials in the Omaha-Council Bluffs area. In
August, 1975 when MAPA reviewed the Step 1 facility
planning application (through the A-95 review process), the
regional planning agency noted that the proposed site for
the facility and portions of the wastewater treatment service
area were located in the floodplain.
In the 1975 - 1977 period, the facility plan was prepared
for the Riverside Lakes Project. At the recommendation of
the U.S. Environmental Protection Agency, the facility was
designed to serve a 10-year population growth in order to
minimize adverse impacts on the floodplain.
EPA's reasons for reducing the project design period included
the following:
. Using the historical growth trend, the necessary
population would not be reached;
. The estimated user charge was excessively high;
. Excess reserve capacity can encourage and
accelerate growth in surrounding areas;
. Of the 297 lots above the 100-year flood elevation,
209 lots are unoccupied and utility serviced.
Prohibition of future development would cause
severe economic hardship; and
. There are approximately 12 occupied lots below
the 100-year floodplain and outside the District
which may be served by the wastewater treatment
plant.
When the Step 2 application for funding was reviewed by
MAPA, several specific questions were raised. The regional
planning agency questioned whether '.adequate florid-proofing
for the treatment facility itself had been included in the
proposal. In addition, the agency questioned the proposed
provision of service to areas in the floodplain (beyond
Written Communication from EPA, Kansas City Office,
May 22, 1978.
-45-
-------
existing residential areas). After further discussion,
however, it was agreed that the ten-year design period
included in the environmental impact appraisal and negative
declaration proposed by the U.S. Environmental Protection
Agency would allow enough growth to provide an adequate tax
base for the area while, at the same time, not providing
sewer service for too large a population in the flood prone
area.
During 1977 and 1978 when the Step 2 and Step 3 grant
applications were considered, the U.S. Environmental Protection
Agency provided additional protection against adverse flood-
plain impacts. As stated in the environmental impact
appraisal and negative declaration prepared by EPA, the
following condition should be placed on the Step 2 and Step
3 facility grants:
"The sewer use ordinance of Sanitary District #177,
Douglas, County, Nebraska shall not permit any
connection which would discharge wastewater into any
collection line, lateral sewer, interceptor, or other
means of conveying wastewater to the treatment plant
if such wastewater originates from any building or
facility which is erected or otherwise placed, after
the date of this agreement, upon land which is a
wetland as defined in Executive Order 11990 dated
May 24, 1977, and/or located in an area subject to
100-year flood as defined by the Federal Insurance
Administration elevation study. Pending the completion
and adoption of the Federal Insurance Administration's
flood elevation study, the 100-year flood elevation
of the Elkhorn River in the vicinity of the district
shall be considered to be 1117.5 feet M.S.L."
As stated in the environmental impact appraisal document,
this condition provides for the protection of environmentally
sensitive areas and constitutes a bilateral agreement
between EPA and the District. The condition may be enforced
by any person and/or agency who has an interest in the
protection of such areas. The grant condition was strongly
supported by MAPA.
The review of the proposed wastewater treatment facility
at Riverside Lakes is continuing, although floodplain
impact and management questions appear to have been resolved.
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The Riverside Lakes situation illustrates two useful points
concerning floodplain development assessment and wastewater
treatment facilities:
1. The Metropolitan Area Planning Agency (MAPA),
through the A-95 process, properly identified
potential floodplain development and impact
questions at an early stage in the facility planning
process and served a useful review role through-
out the '201' planning period; and
2. The U.S. Environmental Protection Agency (Kansas
City Office) played a major role during the Step
1 facility planning process of reducing potential
floodplain impacts by urging a 10-year population
level and by including sewer hook-up restriction
requirements as part of the Step 2 and Step 3
grant.
The involvement of the Metropolitan Area Planning Agency
as well as EPA led to an appropriate resolution of the
floodplain development impact question at Riverside Lakes.
The role of the Federal Insurance Adminstration was to
provide technical information on the location of the flood-
plain and nature of flood hazards.
Although not evaluated in detail, it is believed that this
illustration also reflects the growing awareness of govern-
ment agencies to floodplain development impact and flood-
plain management questions. When the facility plan was
initially reviewed by MAPA, it was felt that a 10-year
projection was reasonable. This would allow Riverside
Lakes to expand its tax base and still not develop areas
of the floodplain which were not already elevated. The
major concern of MAPA and EPA has been to eliminate an
existing water quality problem without encouraging additional
development in the floodplain.
2- Wastewater Treatment Facility Project in Meridian»
Mississippi^;
In Meridian, Mississippi, a wastewater treatment facility
Information provided by Mr. George Collins, Chief, South
Area Operations Branch, Atlanta Regional Office, U.S.
Environmental Protection Agency; Mr. Richard Gingrich, Natural
Resources Manager, Atlanta Regional Office, U.S. Environmental
Protection Agency, and Mr. Glenn Woodard, Regional Director,
Atlanta Regional Office, Federal Insurance Administration.
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was proposed for construction which could affect floodplain
development. The U.S. Environmental Protection Agency and
the Federal Insurance Administration of the U.S. Department
of Housing and Urban Development worked together with the
City of Meridian to resolve the issue.
Prelimary information on the location of the 100-year
floodplain and floodway was available to the City of Meri-
dian from an FIA Flood Insurance Study prepared by the Corps
of Engineers. Regulations of the Federal Insurance Admini-
stration require that communities adopt a floodplain
management ordinance after completion of a Flood Insurance
Study which establishes a floodway. The ordinance must
include the following provision:
Select and adopt a regulatory floodway based on the
principle that the area chosen for the regulatory flood-
way must be designed to carry the waters of the base
flood without increasing the water surface elevation
of that flood more than one foot at any point. (FIA
criteria, 1910.3 (d) (2))
The floodway is the portion of the floodplain adjacent to
the river which includes the overbank area capable of
carrying deep and and fast moving waters.
Meridian's ordinance was due for adoption on or before
December 15, 1977. When the city failed to adopt an
Ordinance, the City was suspended from the National Flood
Insurance Program. The suspension ultimately led to the
conflict with EPA.
When wastewater treatment facilities are constructed in the
floodway, the boundaries of the floodplain are often af-
fected. For this reason, the Federal Insurance Administra-
tion and the U.S. Environmental Protection Agency direct
floodplain facilities to locations outside of the flood-
way and, in some cases, when possible, completely outside
of the floodplain.
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Two positive actions have been taken by the City of Meridian
to resolve the issue and to allow the facility planning and
engineering design process to continue. First, the City
and the Federal Insurance Administration have arranged for
the U.S. Army Corps of Engineers to rerun the floodway
model to determine if a reorientation of the proposed addi-
tion to the wastewater treatment facility would have a dif-
ferent effect on the floodway.
In addition, the City has complied with National Flood In-
surance Program requirements by adopting an ordinance in
compliance with FIA criteria, including floodway controls.
Meridian's ordinance was adopted on March 22, 1978, with an
effective date of April 22, 1978, or 30 days after passage.
Meridian was reinstated into the NFIP effective March 28,
based on the adoption of the ordinance. However, the ordinance
was not acceptable to FIA since it was not effective until
April 22, 1978. In order to assure proper construction
standards in floodplain areas and avoid possible high flood
insurance rates during this 30-day period, a moratorium
was placed on new construction until April 22, 1978, the
effective date of the ordinance.
In addition, the City is complying with National Flood
Insurance Program requirements by adopting an ordinance
which places a moratorium on development in the floodplain,
The City is presently reinstated in the National Flood
Insurance Program and insurance at low rates is available
to community residents.
This example illustrates several points concerning the
identification of floodplain impacts related to wastewater
treatment facilities:
1. Even when floodplain boundary information
and other technical studies are available to
consulting engineers and communities preparing
Step 1 Facility Plan, the information is
not always considered in detail during Step 1t
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2. When major technical impacts are identified
which require additional studies after the
completion of the Step 1 Facility Plan, de-
lays in Step 2 and Step 3 grant approval can
result.
3. The Federal Insurance Administration and the
U.S. Environmental Protection Agency have some
similar concerns related to floodplain impacts
and floodplain management, and can assist each
other in obtaining floodplain management
objectives at the local level. In the case of
the City of Meridian, Mississippi, EPA held up
a '201' grant until the City complied with
requirements of the Federal Insurance Administration.
In turn, the specific requirements of the Federal
Insurance Administration for the adoption of
local floodplain management regulations led to
a development moratorium in the floodplain area.
(Although a moratorium on floodplain development
is not required for admission to the National
Flood Insurance Program, the situation in
Meridian led to federal agency agreement that this
was necessary for the protection of public health
and safety.)
As shown by this example, the Atlanta Regional Office of
EPA addresses floodplain impact issues when they become
apparent.
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CHAPTER THREE
RECOMMENDATIONS FOR THE
IDENTIFICATION AND REDUCTION OF FLOODPLAIN
DEVELOPMENT IMPACTS
A. Introduction
Floodplain management is a complex process, both technically
and administratively. From a technical standpoint, the
location of the floodplain and the effects of various pro-
jects such as wastewater treatment plants must be assessed.
The identification of the magnitude of secondary develop-
ment impacts and the determination of appropriate govern-
ment policy concerning the proper use of the floodplain pose
special challenges for government agencies.
Floodplain management is also complex from an administra-
tive and inter-governmental standpoint. In the past, flood-
plain management has often been left to local governments.
Federal agency concerns and responsibilities have increased
in the past decade, however, and have been recently empha-
sized by President Carter's Floodplain Management Execu-
tive Order. Although local agencies manage many aspects of
the private development approval process, federal agencies
are clearly charged with the responsibility of identifying
and mitigating potential floodplain impacts resulting from
their actions.
The Floodplain Management Executive Order reinforces
existing policies of the U.S. Environmental Protection
Agency concerning floodplain protection and secondary
development. Present policies of EPA emphasize the
following:
Wastewater treatment facilities should, in
general, be located outside of floodplains.
Where such locations are not practicable,
the plant and equipment should be protected
against flooding.!
1U.S. Environmental Protection Agency, "Guidance for Pre-
paring a Facility Plan", Revised, May, 1975, page. 14.
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When wastewater treatment facilities may-
induce construction in the floodplain, re-
sulting flood hazards should be evaluated
and practicable alternatives considered.
The purpose of the evaluation is to "pre-
clude the uneconomic, hazardous, or unneces-
sary use of floodplains, to minimize the ex-
posure of facilities to potential flood
damage, lessen the need for future federal
expenditures for flood protection and flood
disaster and preserve the unique and signifi-
cant public value of the floodplain as an
environmental resource."2
Wastewater treatment facilities projects with
secondary development impacts "should be
identified early and receive attention from
the time they appear on the project priority
list so that suitable agreements can be
reached without delaying the project. Re-
gions should work closely with states and local
communities to ensure that evaluation of en-
vironmental impacts is fully integrated into
the planning process,"3
Given the fact that EPA has broad policies and concerns re-
lated to wastewater treatment facilities and floodplain im-
pacts, then, how can the policies be effectively imple-
mented? The answer to this question must be based upon an
analysis of present floodplain development trends, issues,
and approaches used by the U.S. Environmental Protection
Agency. The major findings from the analysis lead directly
to recommendations for administrative action in EPA.
This chapter recommends approaches for strengthening the:
ability of the '201' Wastewater Treatment Works Program to
identify and mitigate floodplain development impacts.
240 Federal Register No. 72, Section 6.214(b)(2)r U.S.
Environmental Protection Agency, April 14, 1975,
3U.S. Environmental Protection Agency, "Consideration of
Secondary Environmental Effects in the Construction Grants
Process," Program Requirements Memorandum PRM No. 75-26,
June 6, 1975.
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B. Recommendations; Floodplain Impact Mitigation Measures
and the '201' Wastewater Treatment Works Program
Based upon the information collected and assessed over the
past nine months concerning floodplain development pressures,
federal programs, and the '201' Wastewater Treatment Works
Program, recommendations for the identification and reduc-
tion of floodplain development impacts from the '201'
Program are presented.
The recommendations described here pertain solely to flood-
plain protection, which is one of a number of environmental
concerns which must be addressed by the '201' Wastewater
Treatment Works Program. Why recommend special actions
for floodplains alone? Why not address environmental
issues in a comprehensive way?
The reasons for special floodplain recommendations are
two-fold. First, as a result of the activities of the
Federal Insurance Administration, information is available
which may not be present for other environmental resources.
Secondly, if there are some tasks which can be done to
supplement comprehensive environmental reviews with small
amounts of time, they should be seriously considered.
Before implementing floodplain development mitigation
measures, however, the possibility of reducing environmental
impacts on other resources through similar measures should
be reviewed.
Recommendations pertain to the following subjects:
. .Identification of Floodplain Development Pressures
and the '201' Program Planning Process;
Coordination Between the U.S. Environmental Pro-
tection Agency and the Federal Insurance Admin-
istration;
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Interagency Coordination for Floodplain Impact
Mitigation;
The Use of Grant Conditions for Sewer Hookup
Restrictions; and
The Definition of Criteria and Standards for
Floodplain Development Impacts.
The actions recommended should be of assistance in imple-
menting the Executive Order on Floodplain Management as
well as present EPA floodplain protection policies. Each
subject is described below and specific recommendations are
outlined.
1. Identification of Floodplain Development Pressures and
the '201' Program Planning Process
The '201' Wastewater Treatment Works Program is organized
into three stages, which are called Steps. Separate grants
are provided for each Step. Step 1 focuses on the prepara-
tion of a facilities plan; Step 2 provides for engineering
design specifications and Step 3 provides for facility
construction. A detailed description of the '201' Program
is included in Part II of this study titled "Methods Used By
Federal Programs to Reduce Floodplain Development Pressures."
Typically, floodplain development impacts related to waste-
water treatment facilities are not known to Regional Of-
fices of the U.S. Environmental Protection Agency until the
Step 1 Facility Plan has been received A Unless the local
community and consulting engineer have been particularly
sensitive to floodplain development impacts and problems,
alternative locations for the facility service area bound-
aries, and other mitigation measures may not be addressed
in detail in the Step 1 Plan.
1 This fact was highlighted in EPA Regional Office meetings
conducted for this study, as well as the case studies on
"Mitigating Secondary Impacts from the Wastewater Facilities
Program" identified by the EPA Office of Land Use Coordina-
tion.
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The Step 1 Facility Plan is clearly the point in the '201*
process where floodplain impacts should be considered in-
depth and recommendations for resolving impacts made. This
is, in fact, mandated by EPA guidelines and regulations.
However, there are many tasks to be accomplished through
the Step 1 Facility Plan, and it is simply not possible
with available resources to investigate every potential
environmental impact.
It should, however, be possible to examine floodplain
development impacts during the Step 1 stage in those
cases where a potential for adverse impact exists. As
identified by the case studies, floodplain development
pressures do not result from all '201' facility grants.
The National Wildlife Federation '201' Program review,
for example, found floodplain development pressures in
13 percent of the projects reviewed. If '201' projects with
a potential for floodplain impacts could be identified
before Step 1 facility planning was initiated, notification
could be provided to the responsible communities and '201'
studies could examine the question in-detail.
The specific objective of the problem identification effort
should be to identify whether the wastewater treatment
facility is likely to provide service to existing or new
development located in the floodplain. The precise nature
of the impact, mitigation measures, alternative solutions
to wastewater treatment needs, or the detailed boundary of
the floodplain would not need to be identified until
facility planning (Step 1) is initiated.
Recommendations:
The fact that the Federal Insurance Administration has
identified the location of the 100-year floodplain and is
working with local agencies on floodplain managment or-
dinances provides a major opportunity for the U.S. En-
vironmental Protection Agency. In order to identify
proposed '201' Wastewater Treatment Works which potential-
ly can have major impacts on floodplain development, it is
recommended that early consultation with staff from the
Federal Insurance Administration be initiated.
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The responsibility for initiating the contacts rests with
each Regional Office of EPA. After a treatment facilities
priority list for each state has been compiled, a repre-
sentative from EPA should meet with Federal Insurance
Administration staff to review potential problems. Two
tasks could be completed fairly quickly. First, officials
at the Federal Insurance Administration should be requested
to indicate communities on the '201' priority list which
presently have extensive floodplain development or appear to
be experiencing floodplain development pressures. Secondly,
EPA staff should quickly review the proposed '201' facility
planning study boundary with floodplain location maps in
order to indicate the amount of floodplain area within
the study area.
From an administrative standpoint, one or two environmental
specialists or planners in EPA could complete the review of
all priority lists. Detailed engineering expertise or flood
hazard expertise would not be necessary to pinpoint the
potential impacts. The information about potential flood-
plain impacts could then be transmitted to the responsible
EPA facility engineers for review with '201* program ap-
plicants .
EPA staff would emphasize the need for floodplain development
reviews when pre-application conferences are held. Typically,
the need for floodproofing is emphasized during the pre-
application conferences. The need for analysis of floodplain
development pressures could easily be emphasized at this
stage also, provided that the communities with potential
impacts had been identified. EPA staff could also provide
special technical assistance to local communities and en-
gineers on floodplain impact questions for the specified
communities.
In the future, it is possible that '208' areawide water
quality management plans could include this basic task
of potential floodplain development impact identification.
The location and environmental impacts of wastewater treat-
ment facilities is one of many assessments to be completed
through the '208' Program which is also administered by the
U.S. Environmental Protection Agency. To date, however,
most '208' plans have not addressed floodplain development
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questions related to wastewater treatment facilities.2
In continuing '208' planning efforts, new '201' treatment
facility projects will be required to conform with adopted
'208' areawide plans.J This relationship between the
'201' and '208' Programs will facilitate the use of '208'
plans as a means for initial floodplain development impact
identification. It is not expected, however, that con-
tinuing '208' planning will be conducted in all metropoli-
tan areas and states. The '208' Program, then, cannot be
relied upon to provide uniform floodplain impact identifica-
tion, although it can provide assistance when continuing '208'
planning occurs.
The recommended approach to the identification of potential
floodplain development pressures is based upon the premise
that only selected environmental impacts can be examined
in detail during the Step 1 facility planning process. It
also is based upon the premise that local communities
and consulting engineers will focus their efforts on
engineering and cost aspects of facility planning unless
specific EPA requirements encourage particular environmental
studies.
At present, the responsibility for identifying the particular
environmental factors to be examined in detail rests with *
local communities and consulting engineers. A shifting
of part of this responsibility to Regional Offices of the
U.S. Environmental Protection Agency is expected to result
in more effective environmental impact identification
and mitigation.
It is not intended that this preliminary and early iden-
tification of the potential for floodplain development
impacts be a replacement for environmental appraisals or
environmental impact statements. Instead, it is intended
to provide an "early warning" of potential floodplain
impacts so that they can be thoroughly addressed during
the Step 1 facility planning process.
2 Interview with Mr. James Meek and Mr. Carl Myers, Program
Development Branch, Water Planning Division, U.S. Environmental
Protection Agency, Washington, D.C., November 8, 1977.
3 Telephone interview with Ms. Merna Hurd, Director of Water
Planning Division, Office of Water Planning and Standards, U.S.
Environmental Protection Agency, Washington, D.C., May 15, 1978,
— 57 —
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2. Coordination Between the U.S. Environmental Protection
Agency and the Federal Insurance Administration
Recognizing that the Federal Insurance Administration's
National Flood Insurance Program is providing a major source
of floodplain information and floodplain management ap-
proaches to local governments throughout the United States
and resulting in the prevention of some floodplain develop-
ment/ additional coordination between the '201' Program and
the National Floodplain Insurance Program is recommended.
Although some EPA Regional Offices presently contact
FIA offices on a regular basis, a uniform approach for all
offices is not in effect.
The purpose of the coordination should be two-fold. First/
communication and coordination is needed in order to pro-
vide EPA project engineers with basic information about
floodplain hazards, issues, and the National Flood Insurance
Program. The emphasis in the communication should be on
the nature of the floodplain, development problems encoun-
tered, local government regulatory approaches, and require-
ments.
S*econdly, it is important that FIA staff be familiar with
EPA floodplain impact policies and approaches. It is
possible that through their contacts with local communities,
FIA staff can alert persons to EPA policies and hence
initiate early community planning for wastewater treatment
facilities which are compatible with floodplain development.
Recommendations;
In order to facilitate the EPA-FIA coordination and infor-
mation exchange, it is recommended that each EPA Regional
Office designate an environmental specialist to be respon-
sible for floodplain coordination and information dissemi-
nation. The person assigned this responsibility should
assume a leadership role, in addition to passing on informa-
tion about new requirements or regulations which are received
from FIA. Although persons are assigned to coordinate
with FIA in some EPA Regional Offices, according to EPA
and FIA officials, a formalized procedure is not in effect.
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The designated EPA floodplains contact in each Regional
Office would become thoroughly familiar with information
available from the FIA offices, and could complete the re-
view of '201' program priority lists, as previously
recommended. In addition, the floodplains coordinator
would prepare information packages for '201' program
engineers, organize workshops, and assist with facility
plan reviews when floodplain impacts are in question.
The floodplains coordinator would also monitor EPA de-
cisions related to floodplains and help to insure the
evolution of uniform standards and criteria among dif-
ferent EPA program offices within each region.
3. Federal Agency Coordination for Floodplain Impact
Mitigation
As illustrated by the floodplain development case studies,
there is no typical pattern or sequence in which federal
programs occur in local jurisdictions. The sequence of
federal programs reflects the changing characteristics of
federal programs available to local communities. Each
community applies for those programs which meet its needs
at particular times.
Despite variations in the pattern and sequence of federal
programs, federal programs which can allow or stimulate
floodplain development (such as the Federal-Aid to
Highways Program of the U.S. Department of Transportation,
Public Works Programs.of the U.S. Army Corps of Engineers,
and the '201' Wastewater Treatment Works Program of the
U.S. Environmental Protection Agency) sometimes do occur
in the same location at the same time. In such cases, it
is important that the federal agencies take similar ap-
proaches to floodplain development issues. Often several
federal programs together can have a more significant ef-
fect on reducing floodplain development pressures than
a single agency alone can accomplish. This is especially
the case when both highways and sewer lines are involved.
Recommendations:
Because of the varying pattern of federal programs in flood-
plains, a step-by-step procedure for interagency coordi-
nation cannot be outlined. Instead, the U.S. Environmental
Protection Agency must be alert for opportunities for
inter-agency coordination.
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Local agencies and engineers completing '201' Facility Plans
are cognizant of plans and proposals of various
federal agencies. Information about other federal programs
occurring in or near the floodplain and the wastewater
treatment facility should be requested in those communities
where potential floodplain development pressures have been
identified (as recommended previously). Information con-
cerning federal programs occurring near the wastewater
treatment facility and the service area should be included
in the '201' Facility Plan.
If the Step 1 Facility Plan review results in the identifi-
cation of potentially significant floodplain development
pressures and if other federal programs are planned for
or occurring in or near the floodplain, inter-agency con-
tacts or meetings should be initiated by the EPA Regional
Office. The agencies should review community conditions
and the potential impact of all federal programs on flood-
plain development pressures, and then determine a uniform
course of action. A single federal agency policy on flood-
plain development in the particular community , rather
than separate agency policies/ should result. In some
cases, technical assistance in developing appropriate ap-
proaches to floodplain impacts and development from the
Regional Offices of the Federal Insurance Administration
may be useful.
The responsibility for initiating inter-agency coordination
actions rests with the Regional Offices. Formal procedures,
such as inter-agency memoranda or agreements are not ne-
cessary to facilitate the coordination.
In order to carry out this recommendation, Regional Office
personnel must understand and believe in the policy of EPA
and the Floodplains Management Executive Order. The miti-
gation of floodplain development impacts from federal programs
is a federal agency responsibility. Although such mitigation
should not be expected to control all floodplain develop-
ment, it can be a critical factor in certain instances.
4. Use of Grant Conditions for Sewer Hookup Restrictions
When it has been determined that a treatment facility is
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likely to have a significant impact on floodplain develop-
ment, there are a number of different actions which can be
taken to mitigate the impact. Mitigation measures which
have proven useful include project revisions, reduction
of the service area of the treatment facility, phasing of
treatment facilities, and the use of grant conditions.
Grant conditions which restrict sewer hookups are often
attached to Step 2 and Step 3 grants, after the Step 1
Facility Plan has been completed and reviewed by the
Regional Office.
All of these floodplain impact mitigation measures can be
useful in particular situations. In order to avoid delays
in facility planning and construction, the need for
particular mitigation measures should be identified during
the Step 1 facility planning stage and used to develop
the Step 1 Facility Plan. As documented in previous studies
of the Environmental Protection Agency as well as this
study, however, the potential for floodplain development
impacts often is not identified until after the Step 1
Facility Plan has, been completed. Often it is through the
environmental appraisal or an environmental impact
statement that floodplain impacts are described. At this
point, redesign of the facility or additional cost-effective-
ness studies may not be possible. Grant conditioning
is the mitigation measure most appropriate for situations where
additional facility studies are not possible. Since this
is a common occurrence, the use of grant conditions for
sewer hookup restrictions is emphasized in this section.
As noted in several places in this report, the itegal and
administrative effectiveness of using grant conditions
for sewer hookup restrictions is questioned by certain
EPA Regional Office personnel. The issue can be simply
stated as follows: after a facility grant has been re-
ceived by the local sponsor and final construction approved
by EPA, what leverage does EPA have to insure that the
grantee follows the hookup restrictions included in the
grant?
The Office of General Counsel in the central EPA office in
Washington, D.C. has researched the problem of the
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"enforceability" of grant conditions. It is the finding
of the Office of General Counsel that there are legal rem-
edies if grant conditions for a construction grants pro-
ject are violated, either before or after completion of
the project.4 if contract provisions are violated after
the final grant payment by EPA, the federal government has
standing and may go to the U.S. District Court to enjoin
the local agency from violating contract conditions. There
is court precedent to support this approach.
There are, of course, certain practical considerations.
Court cases involve time, resources, and the overall value
of the effort must be weighed before litigation is initiated.
There is no question, however, about the availability of
court action to enforce the conditions.
The legal basis for injunctions would be clarified if con-
struction grants project contracts include statements to
the effect that such grant conditions apply to the life
of the facility. It is recommended that the Washington
Office of EPA draft appropriate language for grant condi-
tions and make it available to Regional Offices for use
with '201' construction grants.
It is, therefore, recommended that grant conditions be used
for sewer hookup restrictions in those instances where
scaling down of the treatment facility project, relocation
of the interceptor and plant, and other mitigation measures
are not possible. It is further recommended that Washing-
ton offices of the U.S. Environmental Protection Agency pre-
pare a package of information about grant restrictions for
sewer hookups, including suggested language and the experi-
ence of Regional Offices in using hookup restrictions, for
the use of project engineers and administrators in Regional
Offices.
5. Definition of Criteria and Standards for Floodplain
Development Impacts
Although the Floodplains Management Executive Order and EPA
policies clearly state the need to avoid floodplain develop-
ment whenever possible, the fact remains that, in some cases,
floodplain development pressures cannot be avoided.
4 Information from Mr. Gerald Yamada, Attorney, Grants,
Contracts and General Administration Division, Office of
General Counsel, U.S. Environmental Protection Agency,
May 16, 1978.
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In cases where floodplain development impacts cannot be
avoided, it may be possible to reduce hazardous conditions
and adverse environmental impacts by following certain
criteria and standards for development. In addition,
it may be possible for federal programs to encourage de-
velopment to occur in locations where adverse impacts from
floodplain development are minimized. It is important that
EPA work toward the development of useful criteria and
standards for reducing impacts when floodplain development
is necessary or inevitable.
Recommendations:
Criteria and standards related to floodplain development
will vary with different types of floodplains. The focus
for the development of such standards should, therefore, be
with Regional Offices of EPA. Coordination among the regions
can then be undertaken by the Washington, D.C. EPA head-
quarters.
It is recommended that/each EPA Regional Office work toward
the development of useful criteria and standards for re-
duction of floodplain impacts in those cases where some
floodplain development must take place. Logically, the
development of such criteria would be the responsibility
of a floodplain coordinator who would monitor EPA decisions
on floodplain development impacts and work closely with the
Federal Insurance Administration to identify '201' projects
which are potential floodplain problems.
The development of criteria and standards is a much needed
element of effective implementation of EPA's floodplains
protection policies. Although the task is a difficult one,
it should result in a clarification of EPA policies as
well as better floodplain protection.
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
. REPORT NO.
EPA 130/1-79-001
2.
3. RECIPIENT'S ACCESSION-NO.
4. TITLE AND SUBTITLE
Floodplain Development Pressures and Federal Programs,
Part I: Gase Study Analysis and Recommendations for the
'201' WaStewat&T Trpaf-tnont- Wm-Vo P-rno-ram
5. REPORT DATE
11/78
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
Lillian F. Dean
3. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
The Research Group, Inc.
1230 Healey Building
57 Forsyth Street, N.W.
Atlanta, Georgia 30303
10. PROGRAM ELEMENT NO.
2HA696
11. CONTRACT/GRANT NO.
68-01-3923
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
addltional volumes which were prepared in support of this re-
port are available from NTIS. They are Part II; Methods Used by Federal Programs
educ e Floodplain Development Pressures, and Part III: Case Studv Reports _
:o R
16. AB
'his study identifies the individual and combined effects of federal programs on
levelopment in the floodplain, and based upon those findings, recommends ways in which
:he '201' Wastewater Treatment Works Program of the U.S. Environmental Protection
Agency can reduce floodplain development pressures. Major tasks in developing those
recommendations are as follows:
(1) Thirty-one case studies of the impact of federal programs on floodplain devel-
•pment weee completed in the Southeast, West, and Midwest regions. Interviews with
planning directors and other knowledgeable persons at the local government level pro-
vided the basic information;
(2) Meetings with the EPA Regional Offices in Atlanta, Kansas City, and Denver were
held to review present methods for implementing floodplain policy related to '201'
wastewater treatment facilities;
(3) Federal programs which potentially can affect floodplain development were
reviewed to identify the range of methods and approaches presently used to mitigate
floodplain development pressures; and
(4) Major decision points in the '201' Wastewater Treatment Works Program which
can affect floodplain impacts were identified, based upon a review of program regula-
tions and guidance materials.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
COS AT I Field/Group
Floodplains
Sewage Treatment
Government Policies
Land Use
Environment
Floodplain development
pressures
Sewage Treatment Impacts
Primary and Secondary
Impact Assessment
13B
08H
05A
8. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLAS.S (This Report)
Unclassified
20. SECURITY CLASS (Thispage)
Unclassified
21. NO. OF PAGES
JJ.
22. PRICE
EPA Form 2220-1 (9-73)
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